HEADNOTES OR EPIGRAPHS

People vs. Yabut

58 SCRA 499 (1933)
Facts:
On August 1, 1932, appellant Antonio Yabut, then a prisoner serving sentence in the
Bilibid Prison, hit Sabas Arceo, also a prisoner in the Bilibid Prison, with a wooden club
inflicting upon various physical injuries on different parts of the body which caused the
latters death after 24 hours. At the time of the commission of the crime, the appellant
was a recidivist, he having been previously convicted twice of the crime of homicide and
once of serious physical injuries, by virtue of final sentences rendered by a competent
tribunal. The Court of First Instance of manila, in punishing the appellant, applied article
160 of the Revised Penal Code which states that: Commission of another crime during
service of penalty imposed for another previous offense PenaltyBesides 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.
The appellant advances that the lower court erred in applying Article 160 of the RPC.
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.
Issue:
Whether or not the term another in the epigraph of Article 160 of the Revised Penal
Code applies only in cases where the new crime is different in character from the former
crime for which the defendant is serving the penalty.
Ruling:
No. It is a 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 for the 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.

Recidivist is one who, at the time of his trial for one crime shall have been previously
convicted by final judgment of another crime embraced in the same title of the RPC.
Habitual delinquent when a person within a period of ten years from the date of
release, or last conviction, is found guilty of the crime of serious or less serious physical
injuries, robbery, theft, estafa, or falsification a third time or oftener.
Quasi-recidivist 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 with the maximum period of punishment prescribed by law for the new
felony.

STAT CON:
Headnotes, headings or epigraphs of sections of a statute are convenient index to the
contents of its provisions. They are prefixed to sections or chapters of a statute for
ready reference or classification. 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.