Title
Parulan vs. Director of Prisons
Case
G.R. No. L-28519
Decision Date
Feb 17, 1968
Ricardo Parulan, serving a commuted sentence, escaped confinement, was recaptured, and prosecuted for evasion of service of sentence. The Supreme Court upheld jurisdiction, ruling evasion as a continuing crime, denying his habeas corpus petition.

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)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster—building context before diving into full texts.