G.R. No. L-8195; February 14, 1913
THE UNITED STATES, petitioner, vs. THE COURT OF FIRST INSTANCE OF MANILA, A.S. CROSSFIELD, JUDGE, ET AL., respondents.

FACTS

On June 24, 1912, a complaint was filed against Joseph M. Heery and Joseph J. Capurro for violating the Opium Law. After trial, the respondent Judge A.S. Crossfield found them guilty on July 30, 1912, and sentenced each to six months imprisonment and an P800 fine. The sentence was read to the defendants on August 2, 1912. On August 5, 1912, the defendants filed a motion to modify the sentence. The hearing on the motion was held on August 10 and later suspended until August 16. The judge then issued an order modifying the sentence to a fine of P2,000 each, which was read to the defendants on August 19, 1912. The petitioner, the United States, filed for a writ of certiorari, arguing that the respondent judge lost jurisdiction to modify the sentence after fifteen days from its rendition, as provided by Section 47 of General Orders No. 58.

ISSUE

Whether the respondent judge retained jurisdiction to modify the original criminal sentence after the lapse of fifteen days from its rendition to the defendants.

RULING

No. The Supreme Court granted the writ of certiorari and annulled the modified sentence. The Court held that under Section 47 of General Orders No. 58, an appeal must be taken within fifteen days from the rendition of judgment, and a sentence becomes final after that period. The pendency of a motion for modification or new trial does not extend this fifteen-day period. Since the modified sentence was announced seventeen days after the original sentence (August 19 from August 2), the respondent judge had lost jurisdiction to alter the sentence. The original sentence of August 2, 1912, remained in full force and effect. The lapse of fifteen days in the Philippines has the same effect on the finality of a judgment as the expiration of a term of court in other jurisdictions.