Title
People vs. Santiago
Case
G.R. No. 32456
Decision Date
Nov 14, 1930
A defendant in the Philippines, Santiago, is found guilty of estafa but cannot be sentenced to an additional penalty for a second crime of estafa due to the reformatory nature of the law and the need for gradual application of additional penalties.
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Case Digest (G.R. No. 32456)

Facts:

  • Gervasio Santiago was the defendant-appellant in "People vs. Santiago."
  • He was convicted of estafa by the Court of First Instance of Manila.
  • The incident occurred on August 27, 1929, when Santiago hired a carretela from Francisco Fulgencio for P1.50.
  • Santiago borrowed 70 centavos from Fulgencio, claiming it was needed for a transaction at the San Miguel Brewery.
  • Instead of returning to pay for the fare, Santiago attempted to flee, leading to his capture by the police.
  • Santiago had a history of estafa convictions, with his last conviction in April 1927.
  • The trial court sentenced him to two years, four months, and one day of presidio correccional, plus an additional nine years for being a habitual criminal.
  • Santiago appealed, arguing that his defense was not adequately considered and that he was not given the benefit of reasonable doubt.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court modified the trial court's judgment.
  • The principal penalty was reduced to one year and one day of presidio correccional.
  • The additional penalty of nine years for habitual delinquency was el...(Unlock)

Ratio:

  • The Supreme Court's decision was based on the interpretation of laws regarding habitual criminals and penalties.
  • The court determined that when a habitual criminal commits multiple crimes without prior convictions, these crimes are treated as one for sentencing purposes.
  • Santiago committed two estafas in quick succession without being convicted of the first before the second.
  • The court concluded that multiple additional penalties could not be imposed i...continue reading

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