Case Summary (G.R. No. L-28519)
Background and Facts
Ricardo Parulan was originally serving a life sentence at Muntinglupa Penitentiary, which was commuted to twenty years by the President of the Philippines. In October 1964, Parulan was transferred to the military barracks at Fort Bonifacio, Makati, Rizal, under the custody of the Stockade Officer. During this time, he escaped from custody but was recaptured in Manila. Subsequently, Parulan was charged with and convicted by the Court of First Instance of Manila for evasion of service of sentence under Article 157 of the Revised Penal Code. He was sentenced on August 3, 1966.
Legal Issue
The core issue raised by the petition is whether the Court of First Instance of Manila had jurisdiction over the crime of evasion of service of sentence committed by Parulan, particularly whether the court lawfully tried the case and imposed the sentence.
Applicable Law and Jurisdiction
Under Section 14, Rule 110 of the Revised Rules of Court, criminal actions must be instituted and tried in the court with jurisdiction over the place where the offense or any essential element of it occurred. The Court distinguished between two categories of crimes:
- Transitory or continuing offenses - where essential acts occur in different places, allowing jurisdiction in any place where the crime took place. Examples include estafa and abduction.
- Continuing offenses by nature - where the violation is persistent over time and place. Examples include kidnapping, illegal detention, and libel distributed in multiple locations.
Analysis of Evasion of Service of Sentence as a Continuing Offense
The Court placed evasion of service of sentence within this latter category of continuing offenses. It reasoned that an escaped prisoner’s offense is not fully consummated upon escape; as long as the prisoner continues to evade service by moving from place to place, the crime endures as a continuous act. This continuity allows the state to arrest the escapee without a warrant at any place where he is found, pursuant to Section 6(c), Rule 113 of the Revised Rules of Court.
The Court cited legal precedents and doctrine to support this concept that the crime of evasion consists of a continuous series of acts motivated by a single impulse. Hence, the Court of First Instance of Manila had proper jurisdiction since the continuing offense extended to Manila, where the petitioner was recaptured.
Conclusion
The writ of habeas corpus was denied. The Court held that the conviction and sentence for evasion of service of sentence were valid, as
Case Syllabus (G.R. No. L-28519)
Nature and Relief Sought in the Case
- The case involves a petition for a writ of habeas corpus filed by Ricardo Parulan, contesting the legality of his confinement.
- The petitioner prays for immediate release from unlawful and illegal detention under the administrative and supervisory control of the Director of Prisons.
- The petition challenges the validity of the sentence imposed for the crime of evasion of service of sentence under Article 157 of the Revised Penal Code.
- Central to the relief is the claim that the sentencing court lacked jurisdiction over both the person of the petitioner and the offense charged.
Factual Background of the Case
- Ricardo Parulan was confined in the state penitentiary at Muntinglupa, Rizal, serving a life imprisonment sentence commuted to twenty (20) years by Presidential prerogative.
- In October 1964, Parulan was transferred to the military barracks at Fort Bonifacio, Makati, Rizal, under custody of the Stockade Officer.
- While serving his sentence, Parulan escaped from confinement but was subsequently recaptured in Manila.
- He was prosecuted before the Court of First Instance of Manila for evasion of service of sentence.
- After a trial, on August 3, 1966, the petitioner was found guilty and sentenced accordingly under Article 157 of the Revised Penal Code.
Legal Issue Presented
- The principal legal question is whether the Court of First Instance of Manila possessed jurisdiction to try and convict the petitioner for evading service of sentence.
- Jurisdiction in criminal cases is anchored on whether the court where the action was instituted corresponds to the place where the offense or any essential ingredient thereof occurred.
- The petitioner argues that the court that tried and sentenced him had no jurisdiction over his person or the offense as charged.
Applicable Legal Principles on Jurisdiction
- Section 14, Rule 110 of the Re