GR 35270; (February, 1932) (Digest)
G.R. No. L-35270. February 24, 1932.
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. DEMETRIO FRANCISCO Y GAAC, defendant-appellant.
FACTS
The defendant-appellant, Demetrio Francisco y Gaac, was convicted of a crime. His counsel admitted that all allegations in the information were proven and the sentence was justified. However, counsel insinuated the case should be remanded because the trial court’s judgment contained no specific findings of fact. The crime was committed under the old Penal Code, and the defendant was deemed an habitual delinquent with prior convictions.
ISSUE
Whether the trial court’s judgment should be reversed and the case remanded due to its lack of specific factual findings.
RULING
No. The Supreme Court affirmed the conviction but modified the penalty. The lack of detailed factual findings in the judgment does not necessitate reversal if the judgment’s findings are sufficient to support it, which they were here. The Court applied the penal laws in force at the time the crime was committed, as the defendant, being an habitual criminal, was not entitled to the favorable retroactive effect of the Revised Penal Code. The appellant was sentenced to four years, two months, and one day of prision correctional for the principal crime, plus an additional three years’ imprisonment for habitual delinquency.
AI Generated by Armztrong.