Case Digest (G.R. No. L-28519) Core Legal Reasoning Model
Facts:
This case involves petitioner Ricardo Parulan who filed a petition for a writ of habeas corpus against the Director of Prisons. Parulan was confined in the state penitentiary at Muntinglupa, Rizal, serving a life imprisonment sentence that was commuted to twenty years by the President of the Philippines. In October 1964, while still serving his sentence, he was transferred to the military barracks at Fort Bonifacio in Makati, Rizal, under military custody. During that month, he escaped from confinement but was later recaptured in Manila. Parulan was prosecuted for the crime of evasion of service of sentence under Article 157 of the Revised Penal Code before the Court of First Instance of Manila. He was found guilty and sentenced on August 3, 1966. Parulan challenged the legality of his detention on the ground that the Court of First Instance of Manila had no jurisdiction over him or the offense charged, thus rendering his confinement illegal. The case was elevated to the Suprem
... Case Digest (G.R. No. L-28519) Expanded Legal Reasoning Model
Facts:
- Identity and petition
- Ricardo Parulan filed a petition for a writ of habeas corpus directed to the Director of the Bureau of Prisons.
- The petition prayed for the immediate release of Parulan from illegal and unlawful confinement.
- The basis of the petition was the allegation that Parulan’s confinement was unlawful because the sentence for evasion of service of sentence was imposed by a court without jurisdiction over him or the offense charged.
- Background of confinement and escape
- Parulan was initially serving a life imprisonment sentence, later commuted to 20 years by the President of the Philippines.
- In October 1964, Parulan was transferred from the state penitentiary at Muntinglupa, Rizal, to the military barracks at Fort Bonifacio (Makati, Rizal), under the custody of the Stockade Officer.
- Parulan escaped from confinement while still serving his prison term.
- He was recaptured in Manila and prosecuted for evasion of service of sentence under Article 157 of the Revised Penal Code.
- Trial and conviction
- Parulan was tried by the Court of First Instance (C.F.I.) of Manila.
- After the trial, he was found guilty and sentenced on August 3, 1966, to the penalty prescribed under the law for the offense.
- Contentions of petitioner and procedural posture
- Petitioner asserted that the court lacked jurisdiction over the person and the offense.
- The question was whether the C.F.I. of Manila had jurisdiction to try and sentence him for evasion of service of sentence.
Issues:
- Whether the Court of First Instance of Manila had jurisdiction to try and impose sentence for the crime of evasion of service of sentence on Ricardo Parulan.
- Whether the imprisonment for evasion of service of sentence was lawful, considering the place and nature of the offense committed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)