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Murder Conviction Appeal: Yabut Case

Antonio Yabut, a prisoner serving a sentence in Bilibid Prison, assaulted and killed another prisoner, Sabas Aseo, by hitting him with a wooden club. Yabut had previously been convicted of homicide and serious physical injuries. Yabut claimed another prisoner committed the crime. However, the court found Yabut guilty of murder and sentenced him to death. The issue was whether Article 160 of the Revised Penal Code, which increases penalties for crimes committed while serving a sentence, applied. The court held that Article 160 unambiguously applied regardless of whether the new crime was different than the original, as the text made no distinction. Headlines and summaries cannot modify clear text.

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106 views2 pages

Murder Conviction Appeal: Yabut Case

Antonio Yabut, a prisoner serving a sentence in Bilibid Prison, assaulted and killed another prisoner, Sabas Aseo, by hitting him with a wooden club. Yabut had previously been convicted of homicide and serious physical injuries. Yabut claimed another prisoner committed the crime. However, the court found Yabut guilty of murder and sentenced him to death. The issue was whether Article 160 of the Revised Penal Code, which increases penalties for crimes committed while serving a sentence, applied. The court held that Article 160 unambiguously applied regardless of whether the new crime was different than the original, as the text made no distinction. Headlines and summaries cannot modify clear text.

Uploaded by

nmbalindong13
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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People v.

Yabut
G.R. No. 39085. September 27, 1933.

THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appelle,


vs.
ANTONIO YABUT, defendant-appellant.

Felipe S. Abeleda for appellant.


Office of the Solicitor-General Hilado for appellee.

This is an appeal from the judgment of the Court of First Instance of Manila, convicting the appellant of
the crime of murder and assessing the death penalty.

FACTS:
On or about the 1st day of August, 1932, the accused Antonio Yabut, then a prisoner serving sentence in
the Bilibid Prison, wilfully, unlawfully, feloniously and treacherously, assault, beat and use personal
violence upon one Sabas Aseo, another prisoner also serving sentence in Bilibid, by then and there hitting
the said Sabas Aseo suddenly and unexpectedly from behind with a wooden club, without any just cause,
thereby causing the death of the latter. Yabut was a recidivist, he having previously been convicted twice
of the crime of homicide and once of serious physical injuries, by virtue of final sentences rendered by
competent tribunals. Yabut alleged that it was Villanueva and not him who has given the fatal blow.
However, the court found him guilty.

ISSUE:
Whether or not Art. 160 of the Revised Penal Code applies to the case at bar.

HELD:
Yes. Art. 160 of the Revised Penal Code, translated in English, provides that:

Commission of another crime during service of penalty imposed for another previous offense — Penalty.
— Besides the provisions of rule 5 of article 62, any person who shall commit a felony after having been
convicted by final judgment, before beginning to serve such sentence, or while serving the same, shall be
punished by the maximum period of the penalty prescribed by law for the new felony.

The appellant places much stress upon the word "another" appearing in the English translation of the
headnote of article 160 and would have us accept his deduction from the headnote that article 160 is
applicable only when the new crime which is committed by a person already serving sentence is different
from the crime for which he is serving sentence. The language is plain and unambiguous. There is not the
slightest intimation in the text of article 160 that said article applies only in cases where the new offense
is different in character from the former offense for which the defendant is serving the penalty.

It is familiar law that when the text itself of a statute or a treaty is clear and unambiguous, there is neither
necessity nor propriety in resorting to the preamble or headings or epigraphs of a section of interpretation
of the text, especially where such epigraphs or headings of sections are mere catchwords or reference aids
indicating the general nature of the text that follows. A mere glance at the titles to the articles of the
Revised Penal code will reveal that they were not intended by the Legislature to be used as anything more
than catchwords conveniently suggesting in a general way the subject matter of each article. Being
nothing more than a convenient index to the contents of the articles of the Code, they cannot, in any event
have the effect of modifying or limiting the unambiguous words of the text.

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