G.R. No. 40373 ; November 24, 1933
JOAQUIN S. TORRES, petitioner-appellant, vs. THE SUPERINTENDENT OF SAN RAMON PRISON AND PENAL FARM, respondent-appellee.

FACTS

The appellant, Joaquin S. Torres, was convicted on September 23, 1931, by the Court of First Instance of Davao, for the crime of estafa on twenty separate informations to which he pleaded guilty. The aggregate penalties imposed totaled eight years and twenty days, including subsidiary imprisonment. On July 5, 1933, he filed a petition for a writ of habeas corpus in the Court of First Instance of Zamboanga, contending that the sentencing court exceeded its jurisdiction by imposing a penalty in excess of the limit set by Article 88, paragraph 2, of the former Penal Code.

ISSUE

Whether the sentencing court exceeded its jurisdiction by imposing an aggregate penalty that violates the maximum limit prescribed under Article 88, paragraph 2, of the former Penal Code.

RULING

Yes. The Supreme Court reversed the lower court’s decision denying the writ of habeas corpus. Applying the doctrine established in People vs. Garalde (50 Phil., 823), the Court held that Article 88, paragraph 2, of the former Penal Code limits the maximum duration of a convict’s sentence to threefold the length of time corresponding to the most severe penalty imposed, even when penalties are imposed for different crimes at different times under separate informations. Since the aggregate penalty imposed on Torres exceeded this statutory maximum, the sentencing court acted without jurisdiction. The lower court was directed to grant the writ of habeas corpus as prayed for.

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