G.R. No. L-35386 September 28, 1972
ARTEMIO RODRIGUEZ, petitioner, vs. DIRECTOR OF PRISONS, respondent.

FACTS

Petitioner Artemio Rodriguez, a national prisoner serving sentences from final judgments in thirteen criminal cases for estafa, filed this petition for habeas corpus challenging his continued detention. He posited three main arguments. First, he claimed his acquittal by the Court of Appeals in a separate but allegedly factually similar estafa case (CA- G.R. No. 09705 -CR) should retroactively apply as the “law of the case” to all his other convictions, invoking the principles applied in Gumabon v. Director of Prisons. Second, he argued that the gross negligence of his former counsel, which led to the dismissal of his appeals in the thirteen cases, amounted to a denial of due process. Third, he contended he had already served his maximum penalty, asserting he was entitled to the “simultaneous service” of all sentences under Article 70 of the Revised Penal Code.

ISSUE

The core issues were: (1) whether the acquittal in one case constituted the “law of the case” for other convictions; (2) whether the dismissal of his appeals due to counsel’s negligence violated due process; and (3) whether he was entitled to simultaneous service of his multiple sentences.

RULING

The Supreme Court denied the petition. On the first issue, the Court distinguished Gumabon, which involved the uniform application of a legal norm (the proper penalty for simple rebellion) to ensure equal protection. Rodriguez’s case involved attempting to apply a uniform finding of fact across different cases with different complainants and evidentiary settings. The “law of the case” doctrine applies only to subsequent proceedings in the same case, not to different ones. His acquittal in one case, based on its specific evidence, did not govern the other thirteen distinct prosecutions. The principles of stare decisis and retroactivity of favorable penal laws were irrelevant here.
On the second issue, the Court held no denial of due process occurred. The right to appeal is statutory, not a natural right. The dismissal of his appeals for failure to file the appellant’s brief within the reglementary period was a proper application of the Rules of Court. The negligence of counsel, which the Court attributed more to petitioner’s own “lethargy and indifference,” binds the client. On the third issue, the Court rejected the theory of simultaneous service for his imprisonment penalties. Article 70 of the Revised Penal Code provides for the juridical accumulation of penalties, limiting confinement to three times the most severe penalty but not exceeding forty years. The provision allowing simultaneous service applies only to disqualifications, censure, suspension, and accessory penalties—not to principal penalties of imprisonment like those imposed on Rodriguez. Therefore, his continued detention was lawful.