People v. Ug
REITERATIONFacts
The Antecedents: Appellants Go Ug (alias Go Yu), Ong Ting (alias Ang Ti), and Hao Ba Lian (alias Mariano Hao) were accused of violating Article 190 of the Revised Penal Code, which pertains to the possession, preparation, and use of prohibited drugs. Procedural History: The Court of First Instance of Manila convicted the appellants. Go Ug was sentenced to six months and one day of prision correccional, a fine of P1,000, and an additional three years for habitual delinquency. Ong Ting received six months and one day of prision correccional, a fine of P500, and an additional two years for habitual delinquency. Hao Ba Lian was sentenced to six years and one day of prision correccional, a fine of P600, and an additional two years for habitual delinquency. All sentences included subsidiary imprisonment in case of insolvency and costs. The Appeal: The three defendants appealed the judgment, specifically challenging the imposition of the additional penalties for habitual delinquency. They argued that the lower court erred in imposing these penalties, contending that habitual delinquency, as defined by law, is applicable only to certain crimes against property and not to violations of Article 190 of the Revised Penal Code.
Issue(s)
Whether the additional penalties for habitual delinquency were correctly imposed on the appellants convicted of violating Article 190 of the Revised Penal Code.
Ruling
The Court modified the appealed judgment by eliminating the additional penalties imposed upon the appellants for alleged habitual delinquency. The conviction for the violation of Article 190 of the Revised Penal Code stands, but the penalties related to habitual delinquency were removed.
Ratio Decidendi
On Issue 1: The Court held that the lower court erred in imposing the additional penalties for habitual delinquency. According to Article 62, No. 5, last paragraph, of the Revised Penal Code, habitual delinquency can only be considered in cases of crimes against property, such as robbery, theft, estafa, and falsification. The law does not extend the application of habitual delinquency to crimes or infringements of law committed under other articles of the Code or other laws, and specifically not to violations of Article 190, which deals with prohibited drugs. The Court disregarded the arguments of the Solicitor-General that the information was insufficient to prove habitual delinquency, as the core issue was the inapplicability of the concept to the crime charged. Therefore, the appeal was deemed amply justified, leading to the modification of the sentence to remove the habitual delinquency penalties.
Main Doctrine
The Court clarified that the concept of habitual delinquency, as defined in Article 62, No. 5 of the Revised Penal Code, is strictly limited to specific crimes against property, namely robbery, theft, estafa, and falsification. The law explicitly states that a person is considered a habitual delinquent if, within a ten-year period from release or last conviction for these enumerated crimes, they are found guilty of any of them a third time or oftener. Consequently, imposing additional penalties for habitual delinquency on individuals convicted of offenses outside this specific list, such as violations of laws on prohibited drugs under Article 190 of the Revised Penal Code, constitutes an error.