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    People V Yabut Keyword: Prison Fight, New Crime Commited - Topic: Headnotes and Epigraphs

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    JOHN CARLO PACALA
    Antonio Yabut, a prisoner serving time in Bilibid Prison, was accused of killing two other prisoners during a fight. Yabut had previous convictions for homicide and serious physical injuries. The court applied Article 160 of the Revised Penal Code to punish Yabut for committing a new felony while imprisoned. Yabut appealed, arguing Article 160 only applies if the new crime is different from the previous ones. However, the court ruled that the language of Article 160 is unambiguous and applies regardless of whether the new crime is the same or different from prior convictions. The court found Yabut guilty of homicide based on Article 160.

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    People V Yabut Keyword: Prison Fight, New Crime Commited - Topic: Headnotes and Epigraphs

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    JOHN CARLO PACALA
    31 views1 page
    Antonio Yabut, a prisoner serving time in Bilibid Prison, was accused of killing two other prisoners during a fight. Yabut had previous convictions for homicide and serious physical injuries. The court applied Article 160 of the Revised Penal Code to punish Yabut for committing a new felony while imprisoned. Yabut appealed, arguing Article 160 only applies if the new crime is different from the previous ones. However, the court ruled that the language of Article 160 is unambiguous and applies regardless of whether the new crime is the same or different from prior convictions. The court found Yabut guilty of homicide based on Article 160.

    Original Title

    PEOPLE v YABUT

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    Antonio Yabut, a prisoner serving time in Bilibid Prison, was accused of killing two other prisoners during a fight. Yabut had previous convictions for homicide and serious physical injuries. The court applied Article 160 of the Revised Penal Code to punish Yabut for committing a new felony while imprisoned. Yabut appealed, arguing Article 160 only applies if the new crime is different from the previous ones. However, the court ruled that the language of Article 160 is unambiguous and applies regardless of whether the new crime is the same or different from prior convictions. The court found Yabut guilty of homicide based on Article 160.

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    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
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    31 views1 page

    People V Yabut Keyword: Prison Fight, New Crime Commited - Topic: Headnotes and Epigraphs

    Uploaded by

    JOHN CARLO PACALA
    Antonio Yabut, a prisoner serving time in Bilibid Prison, was accused of killing two other prisoners during a fight. Yabut had previous convictions for homicide and serious physical injuries. The court applied Article 160 of the Revised Penal Code to punish Yabut for committing a new felony while imprisoned. Yabut appealed, arguing Article 160 only applies if the new crime is different from the previous ones. However, the court ruled that the language of Article 160 is unambiguous and applies regardless of whether the new crime is the same or different from prior convictions. The court found Yabut guilty of homicide based on Article 160.

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    PEOPLE v YABUT

    KEYWORD: PRISON FIGHT, NEW CRIME COMMITED | TOPIC: HEADNOTES AND


    EPIGRAPHS

    FACT
    • Antonio Yabut was a prisoner serving sentence in the Bilibid Prison when he was accused of killing Sabas
    Aseo and another person who is also a prisoner.

    Victim and accused belong to the same Brigada 8-A. What happened is that Yabut was asking another prisoner Carreon
    for the money he owes him. Then Carreon, upon seeing Saulo, asks him for the money he owes him. Carreon then
    slapped Saulo. This started the fight between the prisoners. Yabut was able to get a stick and then he struck it to Aseo’s
    head. The guard, Villafuerte tried to disarm Yabut but Yabut was able to run to the bathroom.

    • At the time of the commission of the crime, Yabut was a recidivist (convicted more than once), of the
    crime of homicide and once of serious physical injuries.
    • CFI of manila applied article 160 of the Revised Penal Code in punishing the appellant. Yabut appealed
    this, contending that the word "another" appearing in the English translation of the headnote of article
    160 means a different type of crime from the one he committed earlier. So, it is not applicable for him
    because his previous conviction was homicide and this new case was murder (with homicide).
    ART 160
    “Commission of another crime during service of penalty imposed for another previous offense –Penalty—Besides the
    provision 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.

    ISSUE
    Whether or not the term “another” in headnote of article 160 of the RPC applies only in cases where the new
    crime is different in character from the former crime

    RULING
    NO.
    • The language is plain and unambiguous. There is nothing in the text of article 160 that said article
    applies only in cases where the new offense is different in character from the the previous offense.
    • There is no necessity to rely on preamble or headings when the statute is clear and unambiguous.

    Headings of sections in the RPC are mere catchwords or reference aids indicating the
    general nature of the text that follows.

    In case of doubt or ambiguity in the meaning of the law or the intention of the legislature,
    they may be consulted in aid of interpretation

    • The Court find the defendant guilty of homicide and, applying article 249 of the Revised Penal Code
    in connection with article 160 of the same

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