G.R. No. L-10849; January 14, 1916
THE UNITED STATES, plaintiff-appellee, vs. LUIS IGNACIO, defendant-appellant.

FACTS:
On February 16, 1912, Luis Ignacio, a minor under fifteen years of age, was convicted of the crime of lesiones graves. Pursuant to Act No. 1438 , instead of incarceration, he was ordered confined in a reformatory institution in Manila until his majority or until reformed. On May 6, 1914, the Governor-General granted him a conditional pardon, with the specific condition “that he shall not again be guilty of any misconduct,” and he was released. Subsequently, on January 4, 1915, Ignacio was again convicted for the crime of lesiones graves. Based on this subsequent conviction, the provincial fiscal filed a complaint alleging a violation of the pardon’s condition. The Court of First Instance of Ilocos Norte conducted an investigation, found that Ignacio had indeed violated the condition of his pardon, and ordered his recommitment to the reformatory to serve the unexpired portion of his original 1912 sentence, to commence after he completed the sentence for his 1915 conviction. Ignacio appealed this order.

ISSUE:
Whether the defendant, by committing a subsequent crime, violated the condition of his pardon, thereby justifying his recommitment to serve the unexpired portion of his original sentence.

RULING:
Yes. The Supreme Court affirmed the decision of the lower court. The Court held that a conditional pardon is a contract between the sovereign and the convict, who, by accepting it, agrees to comply with its terms. The condition “that he shall not again be guilty of any misconduct” was clear and valid. By being convicted of lesiones graves in 1915, Ignacio violated this condition. Upon such violation, the pardon becomes void, and the convict is placed back in the same legal position as before the pardon was granted. Consequently, the original sentence may be enforced, and the convict may be required to serve the remaining unexpired portion. The Court cited established jurisprudence, including U.S. cases, supporting the principle that a violation of a pardon condition results in a forfeiture of the pardon’s benefits. Therefore, the order for Ignacio’s recommitment after serving his subsequent sentence was proper.