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    1 People vs. Yabut

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    A M I R A
    This case involved Antonio Yabut, a prisoner serving time in Bilibid Prison, who assaulted and killed another prisoner, Sabas Aseo, by hitting him from behind with a wooden club. Yabut had previously been convicted of homicide and assault. The issue was whether Article 160 of the Revised Penal Code, which increases the penalty for committing a felony while already serving time for a previous offense, applied in this case. The court held that Article 160 did apply, as the language of the article is unambiguous and does not specify that the new offense must be different than the previous offense. Headings and titles cannot modify or limit the clear text.

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    1 People vs. Yabut

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    A M I R A
    200 views2 pages
    This case involved Antonio Yabut, a prisoner serving time in Bilibid Prison, who assaulted and killed another prisoner, Sabas Aseo, by hitting him from behind with a wooden club. Yabut had previously been convicted of homicide and assault. The issue was whether Article 160 of the Revised Penal Code, which increases the penalty for committing a felony while already serving time for a previous offense, applied in this case. The court held that Article 160 did apply, as the language of the article is unambiguous and does not specify that the new offense must be different than the previous offense. Headings and titles cannot modify or limit the clear text.

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    This case involved Antonio Yabut, a prisoner serving time in Bilibid Prison, who assaulted and killed another prisoner, Sabas Aseo, by hitting him from behind with a wooden club. Yabut had previously been convicted of homicide and assault. The issue was whether Article 160 of the Revised Penal Code, which increases the penalty for committing a felony while already serving time for a previous offense, applied in this case. The court held that Article 160 did apply, as the language of the article is unambiguous and does not specify that the new offense must be different than the previous offense. Headings and titles cannot modify or limit the clear text.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    200 views2 pages

    1 People vs. Yabut

    Uploaded by

    A M I R A
    This case involved Antonio Yabut, a prisoner serving time in Bilibid Prison, who assaulted and killed another prisoner, Sabas Aseo, by hitting him from behind with a wooden club. Yabut had previously been convicted of homicide and assault. The issue was whether Article 160 of the Revised Penal Code, which increases the penalty for committing a felony while already serving time for a previous offense, applied in this case. The court held that Article 160 did apply, as the language of the article is unambiguous and does not specify that the new offense must be different than the previous offense. Headings and titles cannot modify or limit the clear text.

    Copyright:

    © All Rights Reserved
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    The People of the Philippine Islands vs.

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

    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.
    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 statutory construction, 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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