G.R. No. 45490 - People vs. Haloot

The case involves the defendant, Segundino Haloot, who on or about January 16, 1937, in Manila, committed the crime of robbery.
The defendant entered the residence located at No. 901 A. Mabini Street by breaking the wire nettings of a window not meant for entrance or egress, thereby gaining unlawful entry.
Inside the premises, he stole personal properties belonging to J. H. Forest, which included:

The facts charged establish that the crime was committed without the use of arms and that the value of the property taken did not exceed P250.

The defendant was noted to be a recidivist, having been previously convicted on three separate occasions for theft.
The records show that all three prior offenses were committed on the same date, thereby suggesting that for purposes of identifying habitual delinquency they should be considered as one act rather than three distinct convictions.
The recidivism of the accused is treated as an aggravating circumstance in the determination of his sentence.

The crime charged falls under the robbery provision defined in Article 299 (paragraph (a), subsection 1 in connection with the next to the last paragraph) of the Revised Penal Code.
The prescribed penalty for such robbery, committed without arms, is a minimum period of prision correccional in its medium period to a maximum of prision mayor in its minimum period.
The decision discusses the application of the Indeterminate Sentence Law (Act No. 4103) and the concept of the “next lower in degree” penalty which becomes contentious when the prescribed penalty consists of only a single period within a divisible penalty structure.

The trial and appellate courts examined prior decisions, notably People vs. Co Pao and several decisions of the Supreme Court of Spain (notably the decision rendered on June 13, 1872, and subsequent decisions) in interpreting Article 61 of the Revised Penal Code.
The jurisprudence highlights that when the prescribed penalty has only one period, the determination of the “next lower in degree” may be approached analogously as provided in Rule 4 and Rule 5 of Article 61.
The decisions clarify that the reduction of the penalty (by one period) must be consistent, so that the lower penalty begins immediately after the minimum of the prescribed penalty.

Whether the method of reducing the prescribed penalty by one period, as applied by the trial court, is consistent with the rules and analogies set forth in Article 61 of the Revised Penal Code.
How to properly apply the “next lower in degree” concept when the prescribed penalty for the consummated crime is composed of only one period of a divisible penalty.

Whether the recidivist nature of the defendant, established by his previous convictions (committed on the same date), should be counted as multiple convictions or as a single aggravating circumstance.
The impact of recidivism on qualifying the defendant for a heavier penalty as a habitual delinquent.

How the decision reconciles differing precedents, especially the early Spanish decisions (June 13, 1872) versus subsequent ones, in determining the appropriate minimum penalty.
Whether the imposition of the lower penalty following the ministerial reduction method avoids anomalies that would otherwise favor less serious offenses unfairly.

The dissenter (VILLA-REAL, J.) questions whether fixing the minimum of the indeterminate sentence at six months and one day (prision correccional in its minimum period) properly reflects the intended punitive differences, particularly in crimes with and without the carrying of arms.