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