Facts:

On May 24, 1945, Benedicto Jose y Santos was accused of violating Article 159 of the Revised Penal Code through an information filed by the City Fiscal of Manila. The information stated that prior to April 19, 1944, Santos had been convicted in Criminal Case No. 3 by the Court of Special and Exclusive Criminal Jurisdiction of the City of Greater Manila for violating certain provisions of Act No. 65 and Ordinance No. 1 of the then Republic of the Philippines, resulting in a ten-year imprisonment sentence that commenced on April 19, 1944. After serving approximately six months, Santos was granted a conditional pardon by the President of the Republic of the Philippines on October 15, 1944, which stipulated that he should not violate any penal laws. However, while under this conditional pardon, Santos was later convicted of qualified theft in Criminal Case No. A-605 on April 5, 1945, and was sent to the new Bilibid Prison to serve his sentence.

Santos filed a motion to quash th...

Facts:

1. Conviction and Pardon: Benedicto Jose y Santos was convicted on April 19, 1944, by the Court of Special and Exclusive Criminal Jurisdiction of the City of Greater Manila for violating sections of Act No. 65 and Ordinance No. 1 of the so-called Republic of the Philippines. He was sentenced to ten years of imprisonment. After serving six months, he was granted a conditional pardon by the President of the so-called Republic on October 15, 1944, which required him not to violate any penal laws.

2. Subsequent Violation: Prior to April 5, 1945, while enjoying the conditional pardon, Benedicto Jose committed qualified theft in Manila. He was convicted and sentenced for this crime in Criminal Case No. A-605 of the Municipal Court of Manila.

3. Prosecution for Violation of Pardon: The City Fiscal of Manila filed an information accusing Benedicto Jose of violating Article 159 of the Revised Penal Code for breaching the conditions of his conditional pardon.

4. Motion to Quash: Benedicto Jose filed a motion to quash the information, arguing that the judgment and conditional pardon were void because they were issued by a court and government under the Japanese occupation, which he claimed were illegitimate.

5. Lower Court’s Decision: The lower court granted the motion to quash, holding that the judgment and conditional pardon were void, and that Article 159 of the Revised Penal Code did not apply because the pardon was granted by the President of the so-called Republic, not the legitimate government.

6. Appeal: The City Fiscal appealed the lower court’s decision to the Supreme Court.

Issue:

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Ruling:

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Ratio:

1. Validity of the Sentence: The Court held that the sentence was political in nature because it penalized acts that were not criminal under the municipal law of the Commonwealth Government. Under the principle of postliminium, such punitive sentences lose their effect upon the restoration of the legitimate government.

2. Conditional Pardon: The Court ruled that a conditional pardon depends on the validity of the sentence it remits. Since the original sentence was void, the conditional pardon was also ineffective. Therefore, Benedicto Jose could not be prosecuted for violating the conditions of the pardon.

3. Jurisdiction: The Court emphasized that the proceedings of the Court of Special and Exclusive Criminal Jurisdiction were repugnant to the constitutional rights guaranteed by the Commonwealth Constitution, further invalidating the sentence and the pardon.