G.R. No. 102596 - People vs. Enoja

The case involves the appellant, People of the Philippines, and the appellee, Fidel Tan, who was sentenced by the Court of First Instance of Samar in Criminal Case No. 4097.
Under a modified judgment, Tan received an indeterminate penalty ranging from TWO (2) YEARS & FOUR (4) MONTHS (minimum) to FOUR (4) YEARS & TWO (2) MONTHS (maximum) of prision correccional, with accessory penalties including indemnification to the heirs of Sinforoso Volfango P3,000.00 and the payment of costs.
Although Fidel Tan appealed his conviction, his appeal was later dismissed on his own motion by the Court of Appeals on August 1, 1958, rendering the sentence final.

Tan was committed to the Director of Prisons on March 2, 1959, through the provincial warden of Samar; however, instead of being sent to the national penitentiary (Manila), he was retained in the Samar provincial jail.
The provincial warden, acting on his own initiative, applied Articles 97 and 99 of the Revised Penal Code as well as Act No. 2489 to credit Tan with good conduct time allowance.
After serving 2 years, 8 months, and 21 days of confinement in the provincial jail, the warden released Tan on November 23, 1961, based on his computation of good conduct time allowance in accordance with the Revised Rules and Regulations for the Government of Insular and Provincial Prisoners.

On September 6, 1962, the provincial fiscal moved for Tan’s re-arrest and ordered his recommittal to the national penitentiary, alleging that the provincial warden lacked authority to release him with such allowances.
The motion was unopposed, prompting the lower court to require the warden’s appearance on September 21, 1962, to explain:

The reason for keeping the prisoner in the provincial jail rather than transferring him to Manila.
His justification for releasing Tan without an order from the Director of Prisons and prior to the completion of the sentence’s full term.

A communication from the Director of Prisons in 1959 instructed that transfers be withheld due to congestion and riots at the New Bilibid Prison.
Medical reasons justified delaying Tan’s transfer because of his left lumbar injury, thigh issues, and blood in the urine.
He believed that transferring Tan could expose him to additional risks (occasional and undetermined riots) that might aggravate his ailment, and that releasing him without the remand order was in accordance with the governing rules on good conduct credit.

On January 4, 1963, the lower court issued an order denying the fiscal’s petition for recommittal based on the arguments that:

The court lost jurisdiction over the prisoner’s person when he was committed to custody.
Re-arresting Tan would amount to double jeopardy or a deprivation of liberty without due process.
Tan had abided by the judgment and served it in good faith despite the warden’s alleged errors.

A deduction of 5 days is allowed for each month of good behavior during the first two years of imprisonment.
For the next three years, an allowance of 8 days per month is permitted.

Based on these provisions, the warden credited Tan a total of 184 days (or approximately 6 months and 4 days) of good behavior allowance.
Given Tan’s actual confinement period plus the credited time, he still had an unserved portion of his sentence, calculated to be between 10 to 11 months.

The appellant contended that the lower court’s jurisdiction over the execution of the sentence was not terminated upon the convict’s commitment to jail.
It was argued that the warden’s unilateral actions in crediting good conduct and releasing the prisoner were beyond his authority, as Article 99 of the Revised Penal Code vests that power exclusively in the Director of Prisons.
The appellant maintained that allowing such unauthorized actions would lead to discrimination and potential abuse in the treatment of prisoners.

Whether the lower court’s jurisdiction over the convict’s execution of sentence persisted after the prisoner was committed to the custody of the warden.
Whether the court retained the authority to amend or alter the execution of the sentence despite the conviction becoming final.

Whether the provincial warden had the authority to release Tan based on a unilateral interpretation and application of good conduct time allowance without orders from the Director of Prisons.
Whether crediting the prisoner with good conduct time allowance was appropriately done under Articles 97 and 99 of the Revised Penal Code.

Whether ordering Tan’s re-arrest after his release would constitute double jeopardy or deprivation of liberty without due process.
Whether the prisoner’s release based on the alleged good faith under the judgment and refunding actions of the warden was sufficient to absolve the administrative liability.