G.R. No. 48938; September 27, 1943
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. AMADEO CORRAL, defendant-appellant.

FACTS

Amadeo Corral was convicted of falsification of a public document and sentenced to eight years and one day of prision mayor plus a fine. After serving part of his sentence, he was granted a conditional pardon by Governor-General Forbes on July 31, 1913, which he accepted. The conditions of the pardon were: (1) he shall not reside in Manila or Rizal during the period of his sentence, and (2) he shall not again be guilty of any infraction of the law punishable by imprisonment for one year or more. Subsequently, in the general elections of June 5, 1934, Corral voted despite his legal disqualification due to his previous conviction. He was prosecuted and convicted for illegal voting and perjury in election matters. These convictions were affirmed by the Supreme Court on January 31, 1936. Based on these subsequent convictions, he was prosecuted and convicted in the Court of First Instance of Davao for violating Article 159 of the Revised Penal Code, which penalizes a convict who, having been granted a conditional pardon, violates any of its conditions.

ISSUE

Whether Amadeo Corral violated the condition of his pardon that he “shall not again be guilty of any infraction of the law punishable by imprisonment for one year or more” by his subsequent convictions for election offenses, and specifically, whether this condition was limited only to the duration of his original sentence.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court held that the condition of the pardon requiring the appellant not to be guilty of any infraction of the law punishable by imprisonment for one year or more was not limited to the duration of his original sentence. The Court rejected the appellant’s interpretation and his testimony that a prison official had explained the condition as being limited to the sentence period, finding such testimony “abnormal, if not preposterous.” The Court reasoned that a conditional pardon is granted based on the prisoner’s reformation and the assumption he will be law-abiding; limiting the condition against future violations to the sentence period would negate the benefit to society from the pardon. The condition is reasonable and just, intended to deter future criminality. The trial court correctly found a violation of the pardon’s condition. However, the Supreme Court corrected the trial court’s error in applying the Indeterminate Sentence Law, as Section 2 of said law excludes its application to those who violate a conditional pardon. The penalty under Article 159 is prision correccional in its minimum period. The Court modified the sentence to one year, one month, and eleven days of prision correccional.