G.R. No. 40450; January 29, 1934
TIMOTEO EVANGELISTA, petitioner, vs. THE DIRECTOR OF PRISONS, respondent.

FACTS

Petitioner Timoteo Evangelista was convicted in 1928 by the Court of First Instance of Laguna for usurpation of official functions and sentenced to imprisonment. While his appeal was pending, he absconded. He was later found in Hongkong and extradited to the Philippines under the 1889 U.S.-Great Britain extradition treaty based on his convictions in Manila for robbery and impersonating a public officer. Upon his return, he was detained in Bilibid Prison. While detained, the Court of First Instance of Laguna issued an order committing him to serve the earlier sentence for usurpation. Evangelista filed a petition for habeas corpus, arguing his imprisonment under the Laguna court’s order was illegal.

ISSUE

Whether, under the 1889 extradition treaty between the United States and Great Britain, a person extradited may be imprisoned to serve a sentence for a crime other than the one for which his extradition was demanded.

RULING

No. The Supreme Court, applying the doctrine in Johnson vs. Browne, ruled that under the treaty, an extradited person cannot be imprisoned for a crime other than the one for which extradition was sought, even if it was for a prior conviction. The treaty’s manifest intention is to prevent a state from obtaining custody of a person for one purpose and using it for another. Therefore, Evangelista’s confinement under the Laguna court’s order was illegal. However, the writ was denied because he was validly detained for the crimes (robbery and impersonation) for which he was extradited.

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