THE PEOPLE OF THE PHILIPPINE ISLANDS, 

plaintiff-appelle,
vs.
ANTONIO YABUT, defendant-appellant.

G. R. No. 39085    September 27, 1933

Facts:

The appellant, Yabut, was charged in the Court of First Instance of Manila with the
crime of murder. Upon arraignment, the accused plead not guilty. The lower court found the
appellant guilty of murder supported by evidence beyond reasonable doubt. Hence, the
appeal to the Court.

Issue:

Whether or not the lower court erred in applying article 160 of the Revised Penal
Code

Held:

No. The respondent contends that the word “another” in the heading of 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. But, the Court held
that the language of the law plain and unambiguous, and that the heading of the article is
not intended by the Legislature to be used as anything more than catchwords. Therefore, it
cannot have any effect of modifying or limiting the unambiguous words of the text.