GR 37959; (August, 1932) (Digest)
G.R. No. 37959; August 31, 1932
IGNACIO P. PAGUNTALAN, petitioner, vs. THE DIRECTOR OF PRISONS, respondent.
FACTS
Petitioner Ignacio P. Paguntalan was convicted of robbery on October 24, 1927 and sentenced to 10 years’ imprisonment plus an additional 5-year penalty for habitual delinquency. He filed a petition for a writ of habeas corpus, claiming his detention was illegal. He argued that under Article 62, paragraph 5 of the Revised Penal Code and the doctrine in People vs. Santiago, he should not be considered an habitual delinquent. His criminal record showed multiple convictions between 1915 and 1922 for crimes including abduction, estafa, and robbery. He contended that several of his convictions in 1921-1922, due to their proximity and near-simultaneity, should be counted as only one conviction for determining habitual delinquency, and thus the additional penalty was erroneous.
ISSUE
Whether a writ of habeas corpus is the proper remedy to correct an alleged error in the imposition of an additional penalty for habitual delinquency, where the error is one of judgment and not a jurisdictional defect.
RULING
No. The petition for habeas corpus is denied. The Court held that the alleged error in counting multiple near-simultaneous convictions as separate for habitual delinquency purposes is an error of judgment, not an error that nullifies the proceedings. The court that rendered the judgment had jurisdiction over the crime and the defendant. Habeas corpus is not available to correct mere errors of fact or law that do not vitiate the court’s jurisdiction or render the proceedings void. The proper remedy for such an error was by appeal, not habeas corpus. Since the petitioner was detained under a valid and legal judgment, his detention was lawful.
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