Facts: Defendant was convicted for homicide. While serving sentence, he killed another prisoner. He was consequently charged for murder. Yabut alleged that it was Villanueva and not him who has given the fatal blow. However, the court found him guilty. After conviction, he was punished with the maximum period for murder, in accordance with Art. 160 of the Revised Penal Code.
Issue: Whether or not the lower court erred in applying Art. 160.
Held: No
Ratio: Article 160 of the Revised Penal Code states that “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.”
StatCon maxim: Where the text of a statute is clear and unambiguous, there is neither necessity nor propriety to resort to the headings or epigraphs of a section for interpretation of the text, especially where such epigraphs or headings are mere catchwords or reference aids indicating the general nature of the text that follows.
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