Case Digest (G.R. No. L-3972)
Facts:
- Florena Sales filed a habeas corpus petition for her stepfather, Fidel Ariston, against the Director of Prisons.
- Ariston was convicted of frustrated murder on August 31, 1939, and sentenced to 1 year and 8 months to 7 years in prison.
- He served 2 years, 3 months, and 1 day before being released on January 6, 1942, due to a conditional pardon from the President.
- The pardon required him to comply with Philippine penal laws, with violations leading to legal consequences.
- On February 1, 1950, Ariston was recommitted after being convicted of estafa, receiving a sentence of 3 months and 11 days.
- On April 10, 1950, the Executive Secretary ordered his recommitment to serve the remaining portion of his original sentence due to the violation of the conditional pardon.
- The habeas corpus petition argued that the President lacked authority to recommit Ariston without prior prosecution for the violation.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled against the habeas corpus petition, affirming the President's authority to order recommitment for violations of conditional pardons.
- The Court held that Section 64(i) of the Revised Administrative Code and Article 159 of th...(Unlock)
Ratio:
- The Court interpreted relevant laws, noting that Section 64(i) grants the President the power to recommit individuals who violate conditional pardons.
- Article 159 does not repeal this power, as it penalizes violations as a separate offense.
- Legislative intent was to maintain the President's authority in c...continue reading
Case Digest (G.R. No. L-3972)
Facts:
The case involves Florena Sales, who filed an original petition for habeas corpus on behalf of her stepfather, Fidel Ariston, against the Director of Prisons. The events leading to this petition began on August 31, 1939, when Fidel Ariston was convicted of frustrated murder by the Court of First Instance of Camarines Sur. He was sentenced to a prison term ranging from 1 year and 8 months of prision correccional to 7 years of prision mayor. After serving 2 years, 3 months, and 1 day of his sentence, he was released on January 6, 1942, due to a conditional pardon granted by the President of the Philippines. The conditions of this pardon stipulated that he must not violate any penal laws of the Philippines, and any breach would result in legal proceedings against him.
On February 1, 1950, Ariston was recommitted to the custody of the Director of Prisons after being convicted of estafa by the Court of First Instance of Manila. He was sentenced to 3 months and 11 days of arresto mayor and ordered to indemnify the offended party. Subsequently, on April 10, 1950, the Executive Secretary, acting on behalf of the President, ordered Ariston's recommitment to serve the remaining unexpired portion of his original sentence due to his violation of the conditional pardon. The petition for habeas corpus was based on the argument that the President lacked the authority to recommit Ariston without a prior prosecution for the violation of the conditional pardo...