Baking v. Director of Prisons
REITERATIONFacts
1. The Antecedents: Petitioners were convicted of rebellion by this Court in a decision that became final on May 16, 1969. They had been detained for over eighteen years prior to this conviction. The conviction resulted in a sentence of ten years imprisonment for each petitioner. 2. Procedural History: The petitioners, Angel C. Baking and Simeon G. Rodriguez, initially filed a petition for habeas corpus on March 31, 1969, alleging denial of speedy trial. Following their conviction, they filed a motion for early decision and release. A second, identical petition for habeas corpus was filed by Jose Lava and others on June 17, 1969. The respondent Director of Prisons produced the petitioners and, through the Solicitor General, opposed the application of certain penal code articles for sentence deduction. 3. The Petition: The petitioners seek release via habeas corpus, arguing they have served their ten-year sentences. They claim credit for one-half of their eighteen years of preventive detention under Article 29 of the Revised Penal Code, and further seek to apply Article 97 for good conduct time allowances during their detention. The core legal issue is whether Article 97, concerning good conduct allowances, applies to detention prisoners, with the Court examining its interpretation in conjunction with other articles of the Revised Penal Code and relevant jurisprudence, as well as Section 5 of Act 1533.
Issue(s)
Whether Article 97 of the Revised Penal Code, concerning good conduct allowances, is applicable to detention prisoners. Whether detention prisoners are entitled to good conduct allowances under Section 5 of Act 1533.
Ruling
The petitions are denied. Petitioners are not entitled to release as they have not fully served their sentences based on the applicable laws regarding good conduct allowances for detention prisoners.
Ratio Decidendi
On the applicability of Article 97 of the Revised Penal Code to detention prisoners: The Court held that Article 97 of the Revised Penal Code, which grants deductions from the sentence for good conduct, applies only to prisoners who are serving sentence, not to detention prisoners undergoing preventive imprisonment. This interpretation is based on the Spanish text of Article 97, which uses the term "el penado" (a convicted person) and refers to deductions "del tiempo de su condena" (from the period of his sentence). Furthermore, Article 94 of the Revised Penal Code, in the same chapter as Article 97, explicitly states that good conduct allowances are earned by the culprit "mientras este extinguiendo sentencia" (while he is serving sentence). The phrase "any prisoner" in the English text of Article 97 is thus limited to those convicted by final judgment, consistent with the overall statutory scheme of the Revised Penal Code. On the entitlement of detention prisoners to good conduct allowances under Section 5 of Act 1533: The Court found that Section 5 of Act 1533, which allows detention prisoners to earn good conduct allowances if they "voluntarily offer in writing to perform such labor as may be assigned to them," is still subsisting as it was not expressly repealed by the Revised Penal Code. However, the petitioners failed to present any evidence that they had met this condition. There was no intimation that they voluntarily offered in writing to perform labor. Therefore, they could not avail of the benefits granted to detention prisoners under this specific exception. The burden of proof was on the petitioners to show compliance with Section 5 of Act 1533, a burden they did not discharge.
Main Doctrine
Article 97 of the Revised Penal Code, which provides for good conduct allowances, applies only to prisoners who are serving sentence, not to detention prisoners undergoing preventive imprisonment, unless the conditions under Section 5 of Act 1533 are met.