Case Summary (G.R. No. L-62627)
Chronology of Events
Conrado Martin was initially received at NBP on April 22, 1959, to serve a total sentence of 40 years for various crimes. He escaped from custody on multiple occasions: October 14, 1963, May 1, 1965, October 3, 1969, and July 28, 1979. Each time he was recaptured and recommitted. The President of the Philippines commuted his original sentence to 30 years on June 12, 1976. Following his final escape and recapture on August 8, 1979, he was charged with evasion of service of sentence, which added a further two years, four months, and one day to his commuted sentence.
Legal Question
The pivotal issue before the Court is whether the time that Conrado Martin spent outside prison during his various escapes can be counted as time served toward his sentences.
Legal Analysis
The Court concludes that the periods during which the petitioner was at large cannot be considered as service of his sentences. Under the prevailing legal framework, particularly referenced in Article 89 of the Revised Penal Code, penalties must be served in designated penal institutions. The essence of a prison sentence is the deprivation of liberty, which does not occur when the individual is outside the confines of the prison. Thus, the time spent at large, devoid of any institutional confinement, cannot legally contribute to a reduction of the sentence.
Conclusion
Given the lack of merit in the petitioner’s ar
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Case Background
- The case involves a petition for habeas corpus filed by Conrado Martin, who seeks to be discharged from confinement.
- Conrado Martin is incarcerated at the New Bilibid Prison (NBP) in Muntinlupa, Metro Manila, under prisoner No. 51512-P.
- Martin was first received at NBP on April 22, 1959, serving a definite sentence of 40 years for various crimes, which were described as "three-folded."
History of Escapes and Recommitments
- Martin escaped from prison multiple times:
- First escape: October 14, 1963; recommitted on November 28, 1963.
- Second escape: May 1, 1965; recommitted on June 22, 1968.
- Third escape: October 3, 1969; recommitted on October 10, 1969.
- Fourth escape: July 28, 1979; recommitted on August 8, 1979.
- Martin's original 40-year sentence was commut