Gumabon vs Director of Prisons

FACTS OF THE CASE: The petitioners, Gumabon and company were charged for the complex crime of rebellion with murder and other crimes. They invoked the People vs Hernandez doctrine (held that the crime of rebellion under the Revised Penal Code of the Philippines is charged as a single offense, and that it cannot be made into a complex crime) but this was not taken into account by the Supreme Court. They peitioned for habeas corpus but their plea was denied.

CONTENTIONS OF THYE ACCUSED: The accused held on to the court's ruling on Hernandez that the information against the petitioner for rebellion complexed with murder, arson, and robbery was not warranted under Art. 134 of the Revised Penal Code there being no such complex offense. The ruling was not handed down until after their convictions have become final. Since Hernandez served more than the maximum penalty that could have been served against him, he is entitled to freedom, and thus, his continued detention is illegal.

ISSUE: Whether or not Art. 22 of the RPC which gives a penal judgment a retroactive effect is applicable in this case (whether or not judicial decisions favourable to the accused/convicted for the same crime can be applied retroactively).

RULING: Yes. Judicial decisions favourable to the accused must be applied retroactively. Petitioners relied on Art. 22 of the RPC, which states the penal laws shall have a retroactive effect insofar as they favour the accused who is not a habitual criminal. The Civil Code also provides that judicial decisions applying or interpreting the Constitution forms part of our legalsystem. Petitioners even raised their constitutional right to equal protection, given that Hernandez et al., has been convicted for the same offense as they have, though their sentences were lighter. Habeas corpus is the only means of benefiting the accused by the retroactive character of a favorable decision.

Contention of the Director of Prisons: Maximum penalty for the accused due to the reason that the case at hand was a complex crime of rebellion with multiple murder, robbery, arson and kidnapping.

Additional sa ruling of case 1 as a conclusion: the petition for habeas corpus is granted, and it is ordered that petitioners be forthwith set at liberty.

US vs Look Chaw

FACTS: Look Chaw was accused to have carried carried, kept, possessed and had in his possession and control, 96 kilogrammes of opium and that he had been surprised in the act of selling 1,000 pesos worth prepared opium.

CONTENTION OF THE ACCUSED: He said that more than one crime was charged in the complaint. The defendant moved for the dismissal of the case, on the ground that the court had no jurisdiction to try the same and facts concerned therein did not constitute a crime.

CONTENTION OF THE COURT: The fiscal asked that the maximum penalty of the law be imposed upon the defendant, in view of the considerable amount of opium seized.The court decided that it did not lack jurisdiction, inasmuch as the crime had been committed within its district or the wharf of Cebu. The court was in favor of the government and against the defendant.

ISSUE: Whether courts of local state can exercise its jurisdiction over foreign vessels stationed in its port.

RULING: The mere possession of a thing of prohibited use in these islands, aboard a foreign vessel

in transit, in any of their ports, does not, as a general rule, constitute a crime triable by the courts of this country, on the account of such vessel being considered as an extension of its own nationality, the same rule does not apply when the article, whose use is prohibited within the Philippine islands, in the present case, a can of opium, is landed from the vessel upon the Philippine soil, thus committing an open violation of the penal law in force at the place of the commission of the crime, only the court established in the said place itself has competent jurisdiction, in the absence of an agreement under an international treaty.

The defendant was found guilty of the crime.