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Updated 22nd March 2025
Caraos vs. Daza
Jose Caraos, convicted of homicide in 1944, was released from prison during the Japanese occupation. After liberation, he was rearrested to serve the remainder of his sentence. Caraos claimed he was pardoned, but the court found insufficient evidence to support this claim and denied his petition for habeas corpus.

Primary Holding

The Supreme Court held that there was no competent evidence to prove that Caraos was pardoned, and thus, his rearrest and continued imprisonment were lawful.

Background

Jose Caraos was convicted of homicide in 1944 and sentenced to prison. During the Japanese occupation, he was released from jail, allegedly due to a pardon. After liberation, he was rearrested to serve the unexpired portion of his sentence. Caraos filed a petition for habeas corpus, claiming his release was due to a valid pardon.

History

  • May 3, 1944: Caraos convicted of homicide and sentenced to prison.

  • November 9, 1944: Caraos released from prison during Japanese occupation.

  • February 8, 1946: Investigation conducted by Provincial Fiscal Alano.

  • March 6, 1946: Warrant for Caraos' rearrest issued.

  • March 7, 1946: Caraos confined in provincial jail.

  • March 26, 1946: Petition for reconsideration denied.

  • May 23, 1946: Supreme Court decision.

Facts

  • 1. Caraos was convicted of homicide and sentenced to prison in 1944.
  • 2. He was released from prison in November 1944, allegedly due to a pardon.
  • 3. After liberation, Caraos was rearrested to serve the remainder of his sentence.
  • 4. Caraos claimed his release was due to a pardon, but no evidence was presented to support this claim.

Arguments of the Petitioners

  • 1. Caraos argued that he was released due to a pardon granted during the Japanese occupation.
  • 2. He claimed that his relatives and friends had worked for his pardon.
  • 3. He argued that his rearrest was illegal and that he should be released.

Arguments of the Respondents

  • 1. Respondents argued that Caraos was released due to emergency conditions, not a pardon.
  • 2. They claimed that Caraos was required to serve the remainder of his sentence after normal conditions were restored.
  • 3. They argued that the court had jurisdiction to order Caraos' rearrest.

Issues

  • 1. Whether Caraos was pardoned and thus lawfully released from prison.
  • 2. Whether the court had jurisdiction to order Caraos' rearrest.

Ruling

  • 1. The Supreme Court ruled that there was no competent evidence to prove that Caraos was pardoned.
  • 2. The court found that Caraos was released due to emergency conditions, not a pardon.
  • 3. The court held that Caraos' rearrest and continued imprisonment were lawful.
  • 4. The petition for habeas corpus was denied.

Doctrines

  • 1. Pardon: The court emphasized that a pardon must be granted by competent authority and proven with competent evidence.
  • 2. Jurisdiction: The court affirmed its jurisdiction to order the rearrest of a prisoner who was improperly released.

Precedents Cited

  • 1. Sameth v. Director of Prisons: Cited to establish that only the President or the Commander in Chief of the Japanese imperial forces could grant pardon during the occupation.
  • 2. United States v. Zapanta and Lampano: Cited to emphasize that an unsigned and uncertified copy of a pardon is not competent evidence.
  • 3. Cabantag v. Wolfe: Cited to state that in case of an invalid pardon, the original sentence must be carried out.

Statutory and Constitutional Provisions

  • 1. Rule 124, Section 5, Rules of Court: Cited to affirm the court's inherent powers to compel obedience to its judgments and orders.
  • 2. Revised Administrative Code, Section 64(i): Cited to affirm the Chief Executive's power to order the arrest of a prisoner.