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Aniceto Alcantara vs.

Director of Prisons
(G.R. No. L-6, 29 November 1945, 75 Phil 494)
Ponente: Justice Feria
Doctrine A punitive or penal sentence becomes that of a political complexion when
it penalizes either a new act not defined in the municipal laws or acts already
penalized by the latter as a crime against the legitimate government, but taken out
of the territorial law and penalized as new offense committed against the belligerent
occupant.
Type of Action/Appeal: Petition for writ of habeas corpus by Alcantara on the
ground that he was unduly deprived of liberty due to rendition of the judgment
against him for felony of illegal discharge of firearms with less serious physical
injuries by CFI Ilocos Sur, which was affirmed with modification by Court of Appeals
of Northern Luzon.
Facts Aniceto Alcantara was convicted in the CFI Ilocos Sur in Criminal Case 23
for the felony of illegal discharge of firearms with less serious physical injuries. Upon
his appeal, the Court of Appeals of Northern Luzon in Baguio City modified his
sentence to an indeterminate sentence ranging from 4 mos. and 21 days of arresto
mayor to 3 years, 9 mos. and 3 days of prision correctional.
Issues W/N the Court of Appeals of Northern Luzon had jurisdiction over the case
of Alcantara, on the ground that it was a validly-created court (Court of Appeals of
Northern Luzon was created during the Japanese occupation) and that it has
authority to hold sessions in Baguio City, in relation to Commonwealth Act No. 3?
Verdict Petition for writ of habeas corpus by Alcantara was DENIED.
Held The Court held that the sentence served by Alcantara (illegal discharge of
firearms with less serious physical injuries) is an criminal act that has no political
complexion.
A punitive or penal sentence becomes that of a political complexion when it
penalizes either a new act not defined in the municipal laws or acts already
penalized by the latter as a crime against the legitimate government, but taken out
of the territorial law and penalized as new offense committed against the belligerent
occupant.
It cited the case of Co Kim Cham vs Valdez, where the Japanese Republic (of the
Philippines) and the Phil. Executive Commission were governments de facto and the
judicial acts of the courts thereof were good and valid and remained as such even
/archibald.manansala
Archibald Jose T. Manansala
CEU School of Law and Jurisprudence, A.Y. 2015-2016

Aniceto Alcantara vs. Director of Prisons


(G.R. No. L-6, 29 November 1945, 75 Phil 494)
after the Commonwealth Government was restored, except those crimes with
political complexion (political crimes)
Also, there was no substantial change in the jurisdiction and structure of the Court
of Appeals when the Japanese-initiated Republic abolished the pre-World War II
Court of Appeals, and reorganized it into several courts.

/archibald.manansala
Archibald Jose T. Manansala
CEU School of Law and Jurisprudence, A.Y. 2015-2016