G.R. No. L-3822; July 31, 1951
The People of the Philippines, plaintiff-appellee, vs. Francisco Feliciano (alias Tarzan), defendant-appellant.

FACTS

Francisco Feliciano, along with Ernesto and Fidel Feliciano, was initially charged with murder. After a preliminary investigation, only Francisco Feliciano was charged with murder in the Court of First Instance. On March 30, 1950, with his counsel and the Provincial Fiscal present, Feliciano pleaded guilty to the lesser charge of homicide, admitting to two mitigating circumstances (incomplete self-defense of a relative and lack of education). The court, Judge Roman Campos presiding, accepted the plea and immediately sentenced him to eight months of prision correccional and a P6,000 indemnity. The order of commitment was issued the same day, and the Provincial Warden’s receipt confirmed Feliciano began serving his sentence on March 30, 1950. On April 10, 1950, the private prosecutor filed a motion for reconsideration, which was heard by Judge Jose P. Flores. On April 14, 1950 (promulgated April 15), Judge Flores set aside the original decision and imposed a heavier indeterminate penalty. The defendant appealed.

ISSUE

Whether Judge Flores’ order modifying the original sentence is valid.

RULING

No, the modifying order is null and void. The Court ruled that Judge Flores’ order was issued beyond the 15-day period within which a court may modify its decision, as it was promulgated 16 days after the original decision of March 30, 1950. Furthermore, the defendant had already commenced serving the sentence imposed by the original decision on March 30, 1950, as evidenced by the commitment order and the warden’s receipt. Once a defendant begins serving a sentence, the decision becomes final and can no longer be altered. Therefore, the order of April 14, 1950, is set aside, and the original decision of March 30, 1950, is declared in full force and effect.