G.R. No. L-2092; April 6, 1948
JUSTO CAMAT, petitioner, vs. THE DIRECTOR OF PRISONS, respondent.

FACTS

Petitioner Justo Camat was sentenced on June 30, 1944, by the Court of Special and Exclusive Criminal Jurisdiction to six years’ imprisonment and a fine for illegal possession of firearms. He was released on February 5, 1945, under a mass conditional pardon issued by a Japanese detachment commander. On February 20, 1947, he was arrested for robbery and detained. On February 25, 1948, the Director of Prisons, considering the Japanese pardon null and void, changed Camat’s status from a detention prisoner to a convict serving his 1944 sentence. Camat challenged this transfer, arguing his conviction was null under the ruling in Peralta vs. Director of Prisons.

ISSUE

Whether the Director of Prisons acted illegally in changing Camat’s status from detention prisoner to convict based on a conviction by the Court of Special and Exclusive Criminal Jurisdiction for illegal possession of firearms during the Japanese occupation.

RULING

Yes. Following the precedent in Peralta vs. Director of Prisons, the crime of illegal possession of firearms during the occupation was a political crime, and the judgment of the Court of Special and Exclusive Criminal Jurisdiction ceased to be valid upon the liberation of the Philippines. Therefore, Camat’s conviction was null and void. The Director of Prisons is ordered to immediately restore Camat to his status as a detention prisoner. The Court declined to act on Camat’s prayer for the prosecution of the Director, leaving that to the appropriate administrative or prosecuting officers.

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