People v. Zavala Figueroa

78 P.R. 461
CourtSupreme Court of Puerto Rico
DecidedJune 30, 1955
DocketNo. 11478
StatusPublished

This text of 78 P.R. 461 (People v. Zavala Figueroa) is published on Counsel Stack Legal Research, covering Supreme Court of Puerto Rico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Zavala Figueroa, 78 P.R. 461 (prsupreme 1955).

Opinion

Mr. Justice Marrero

delivered the opinion of the Court.

Defendant prays for the dismissal of the appeal filed by the People in the above-entitled case. He alleges in his brief that on or about May 25, 1953, he filed in the Superior Court a motion praying the Court to set aside the judgment of life imprisonment imposed on him by the former District Court on October 7, 1946;1 that on July 19, 1954, the Superior Court granted his motion and set aside the judgment rendered against him; that four days later the prosecuting attorney filed a motion for reconsideration and on July 30 that motion was denied; that on August 6, 1954, The People [463]*463appealed to this Court both from the decision of July 19 and from that of July 30; and that this Court lacks jurisdiction to entertain the appeal, because it was not filed within the statutory term, citing § § 348 and 349 of the Code of Criminal Procedure and the case of People v. Soto, 72 P.R.R. 385.

Opposing appellee’s motion, the prosecuting attorney contends that the “Motion to Set Aside Judgment” filed by defendant partakes of the nature of and is substantially and fundamentally a habeas corpus proceeding; that the direct attack against a judgment by means of a motion has the same objective as a habeas corpus proceeding when the judgment has been rendered without jurisdiction; and that since the motion to set aside the judgment is analogous to a habeas corpus proceeding and both the motion and the habeas corpus áre of a civil nature, the term for appeal must be computed in accordance with the provisions of the Code of Civil Procedure.

Pursuant to § 348 of the Code of Criminal Procedure, an appeal may be taken by the People “. . . 5. From an order made after judgment, affecting the substantial rights of the people.” Therefore, there is no doubt that the People could have appealed from the orders entered on July 19 and 30. However, pursuant to the provisions of § 349 of the Code of Criminal Procedure, as amended by Act No. 51 of April 20, 1949 (Sess. Laws, p. 128), “An appeal from a judgment must be taken within fifteen days.after its rendition, and from an order, within five days after it is made.” This case is not an appeal from a judgment, but an appeal from an order. If § 349 supra is applicable, naturally, the appeal must be dismissed for lack of jurisdiction, since it was not taken within the five days fixed in that Section.

The prosecuting attorney, as we have seen, contends that the defendant’s motion to set aside the judgment is equivalent substantially and fundamentally to a habeas corpus proceeding. Perhaps he is right, since, as we have [464]*464said on different occasions, the name or title given to a motion does not determine its intrinsic nature.

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Related

People v. Paiva
190 P.2d 604 (California Supreme Court, 1948)
Bowen v. United States
134 F.2d 845 (Fifth Circuit, 1943)

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Bluebook (online)
78 P.R. 461, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-zavala-figueroa-prsupreme-1955.