G.R. No. L-4164 - IN RE: Infante vs. Provincial Warden of Negros Occidental

Case Summary (G.R. No. L-4164)

Key Dates

June 21, 1927: Infante begins serving his sentence.
March 6, 1939: Infante is granted a conditional pardon.
April 25, 1949: Infante is found guilty of driving without a license.
July 13, 1950: Infante is recommitted to custody for violating his pardon.

Applicable Law

The Revised Administrative Code and provisions of the Revised Penal Code are relevant to this case, particularly Section 64(i) of the Revised Administrative Code concerning conditional pardons and Article 159 of the Revised Penal Code concerning violations of such pardons.

Procedural Background

Infante filed a petition for a writ of habeas corpus after being recommitted to prison for violating the conditions of his pardon. The lower court ruled in favor of Infante, leading to an appeal by the Provincial Fiscal, who argued that Infante’s re-arrest was justified under the applicable legal provisions.

Conditional Pardon and Its Condition

Infante's conditional pardon included the stipulation that he would "not again violate any of the penal laws of the Philippines." After his conviction for a motor vehicle offense in 1949, he was arrested for breaching the terms of this pardon. The main contention revolved around whether Infante's reclamation to custody under Section 64(i) of the Revised Administrative Code was valid, given the assertion that this section had been abrogated.

Legislative Intent and Rulings

The court referenced prior rulings regarding the status of Section 64(i), affirming its enforceability and the authority it confers upon the President to revoke the conditional pardon. It clarified that both Article 159 and Section 64(i) could be operational simultaneously: the violation of the conditional pardon may trigger reimprisonment without precluding separate criminal liability.

Prescription of Penalties

Infante argued that the penal consequence associated with his breach of the pardon had prescribed. However, the court clarified that the period for prescription starts from the evasion of the sentence, not from the crime committed post-pardon. Since there was no evasion in this case as Infante enjoyed a form of liberty under the conditional pardon, the court dismissed this contention.

Interpretation of Conditional Pardon Conditions

The court noted that conditions should be strictly construed in favor of the grantee, urging that the violation condition did not extend indefinitely beyond the residual sentence period. The case of Huff vs. Dyer was cited, suggesting that conditions should not overwhelm the nature of pardon, which is intended as an act of grace. The decision emphasized the necessity of interpreting the conditional aspect of pardons to prevent oppressive outcomes.

Good Conduct and Public Policy Considerations

The justices made a policy analysis weighing the implications of punitive measures for a law-abiding individual, like Infante, against the governance prerogatives related to public order. It was argued that if a convict maintains good behavior after serving time, reimprisonment may be excessive, leading to considerations of civil liberties balanced against the necessity of upholding law compliance by persons granted conditional pardons.

Final Judgment

The court ul