Case Digest (G.R. No. 14284-85)
Facts:
William Pomeroy and Celia Mariano Pomeroy v. The Director of Prisons and the Superintendent of Correctional Institution for Women, G.R. Nos. 14284-85, February 24, 1960, the Supreme Court En Banc, Reyes, J., writing for the Court.On June 7, 1952, William Pomeroy and Celia Mariano were charged in the Court of First Instance of Manila (Criminal Case No. 19166) with the complex crime of rebellion with murder, arson and robbery. They were arraigned on June 18, 1952, pleaded guilty, and the trial court found them guilty as charged and sentenced both to reclusion perpetua; they began serving their sentences the same day.
On August 18, 1958, the spouses filed separate petitions for writs of habeas corpus in the Court of First Instance of Rizal. They relied on subsequent Supreme Court decisions — notably People v. Hernandez, People v. Geronimo, and People v. Togonon — which had held that acts of violence committed in pursuance of rebellion did not form a complex crime and that rebellion is punishable under Articles 134 and 135 of the Revised Penal Code by prision mayor (with a fine), not by reclusion perpetua. The petitioners argued that, because of those decisions, the reclusion perpetua sentence imposed upon their 1952 conviction exceeded the lawful penalty; after applying good conduct time allowances and credit for preventive imprisonment they claimed they had served the maximum lawful term and sought immediate release.
The Court of First Instance of Rizal, despite the Solicitor General’s objections, granted the petitions by decision of August 27, 1958 and ordered the release of the petitioners unless other legal cause existed for th...(Subscriber-Only)
Issues:
- Is habeas corpus a proper remedy to challenge a final criminal sentence alleged to be excessive when the sentencing court had jurisdiction?
- Do subsequent Supreme Court decisions holding that rebellion cannot be complexed with common crimes apply retroactively so as to render the petitioners’ prior reclusion perpetua sentence void a...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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