Kabigting v. Acting Director of Prisons
REITERATIONFacts
1. The Antecedents: Jose Kabigting has been serving prison terms since January 5, 1938, based on final judgments of conviction in nineteen criminal cases. The core of the dispute revolves around the computation of his total sentence and the good conduct time allowances to which he is entitled. 2. Procedural History: This case represents Kabigting's third petition for habeas corpus. His first petition was denied by the Court of First Instance of Rizal in 1956. His second petition, filed in 1957, was also denied and subsequently appealed to the Supreme Court (G.R. No. L-12276). In that appeal, the Supreme Court remanded the case for a precise calculation of his remaining sentence after accounting for good conduct time, instructing that if the unserved balance was less than the allowances, he should be released. The Director of Prisons' report indicated a substantial unserved balance, leading to the dismissal of the second petition by the lower court. 3. The Petition: Kabigting filed a third petition for habeas corpus in the Court of First Instance of Rizal, alleging he had overserved his sentence by two months and six days as of November 7, 1958. The lower court, disregarding the Supreme Court's prior ruling in G.R. No. L-12276, found that Kabigting had indeed served his full sentence and ordered his release. The Director of Prisons appealed this decision, arguing that the lower court erred by not adhering to the Supreme Court's final judgment, which had already determined the unserved portion of Kabigting's sentence. The appeal also questioned the timeliness of the respondent's appeal and the premature release of the petitioner.
Issue(s)
Whether the appeal filed by the respondent Director of Prisons was timely. Whether the release of the petitioner rendered the decision appealed from final and executory. Whether the Court of First Instance erred in granting the petition for habeas corpus despite a final Supreme Court decision on the same grounds.
Ruling
The Supreme Court set aside the decision of the Court of First Instance dated April 25, 1959. It affirmed the orders of April 29 and May 29, 1959, regarding the re-arrest of the petitioner. The case was remanded to the court below with instructions to cancel the bonds filed by the petitioner and to issue an order of recommitment so that the petitioner may serve the unexpired term of his aggregate prison sentences, in conformity with the Supreme Court's decision in G.R. No. L-12276.
Ratio Decidendi
On the timeliness of the appeal: The appeal was timely. Section 18 of Rule 41 requires an appeal in habeas corpus cases to be perfected within twenty-four (24) hours from notice of the judgment. Section 1 of Rule 28 provides that when computing time, Sundays and legal holidays are excluded. The respondent received notice of the decision on Saturday, April 25, 1959. Since the next day was a Sunday, the 24-hour period did not include Sunday. Therefore, the appeal filed on Monday, April 27, 1959, was within the reglementary period. On the effect of the petitioner's release: The release of the petitioner was premature and contrary to law. Section 20 of Rule 41 states that a judgment releasing a detained person shall not be effective until the detaining officer has been given an opportunity to appeal, and such appeal shall stay the order of release unless the detainee furnishes a satisfactory bond. The petitioner's release before the appeal period expired and without the detaining officer having had an opportunity to appeal was unlawful. The subsequent posting of bail was a consequence of the premature release and did not render the decision final. On the propriety of the CFI's decision: The CFI erred in granting the petition for habeas corpus and disregarding the final judgment of the Supreme Court in G.R. No. L-12276. The Supreme Court, as the court of last resort, is the final arbiter of legal questions. Its decisions, once final, are binding on all inferior courts and cannot be altered or modified by them. The petitioner's remedy was to seek reconsideration of the Supreme Court's decision, not to file a new petition in an inferior court on the same grounds. The Supreme Court's resolution of April 3, 1959, clearly indicated its stance against successive petitions rehashing decided issues. The CFI's decision directly contravened the principle of res judicata and the doctrine of the law of the case.
Main Doctrine
A lower court cannot disregard a final and executory decision of the Supreme Court on the same grounds and evidence, as such decision constitutes the law of the case and is binding on all inferior courts. A premature release of a detainee contrary to law and pending appeal stays the order of release unless a satisfactory bond is furnished.