Case Summary (G.R. No. L-3994)
Relevant Charges and Penalties
The petitioner was initially charged in the Municipal Court of Dagupan under Article 155, paragraph 4, of the Revised Penal Code, which penalizes any individual who causes a disturbance in public places while intoxicated. Upon pleading guilty, Llobrera received a one-month imprisonment sentence for this violation. Furthermore, due to his prior convictions for similar offenses, he was also subjected to an additional penalty of 2 years, 4 months, and 1 day imprisonment under the habitual delinquency law.
Grounds for Petition
Llobrera's primary argument in his petition for habeas corpus is that the additional penalty imposed on him is null and void. He contends that the habitual delinquency law, specifically Article 62 of the Revised Penal Code as amended by Republic Act No. 18, only applies to specified crimes, namely serious or less serious physical injuries, robbery, theft, estafa, or forgery, and does not extend to the crime of public disturbance defined under Article 155.
Position of the Solicitor General
In response to the petition, the Solicitor General supported Llobrera's claims. The recommendation emphasized that the additional penalty was beyond the Municipal Court’s power, thereby rendering it void. Citing precedents from previous cases (Cruz vs. Director of Prisons and People vs. Costosa), the Solicitor General noted that the imposition of an additional penalty for habitual delinquency must be considered when assessing a court's jurisdiction.
Court's Conclusion
The Court concluded that the additional penalty against Llobrera was indeed void, as it exceeded the jurisdiction of the Municipal Court, which could not impose such a sentence under the circumstances provided by the law. Consequently, the petit
...continue readingCase Syllabus (G.R. No. L-3994)
Case Citation
- Citation: 87 Phil. 179 EN BANC
- Case Number: G.R. No. L-3994
- Decision Date: August 16, 1950
Parties Involved
- Petitioner: Juanito Llobrera y Baylon
- Respondent: The Director of Prisons
Nature of the Case
- The case is a petition for habeas corpus filed by the petitioner, Juanito Llobrera y Baylon, seeking his release from custody following an additional penalty imposed upon him.
Background of the Case
- Initial Charge: The petitioner was charged in the Municipal Court of Dagupan for violating Article 155, paragraph 4 of the Revised Penal Code, which penalizes anyone who causes disturbances or scandals in public places while intoxicated or otherwise.
- Plea and Sentencing:
- Petitioner pled guilty to the charge.
- He was sentenced to one month imprisonment for the initial offense.
- An additional penalty of 2 years, 4 months, and 1 day of prision correccional was imposed under the habitual delinquency law due to two previous convictions for the same offense.
- Current Status: The petitioner served the one month imprisonment and was committed to New Bilibid Prisons in Muntinglupa to serve the additional penalty.
Legal Grounds for Petition
- Argument for Nullity: The petitioner argues that the additional penalty is null and void