United States v. Esteban

Summary

Leon Esteban was convicted of violating section 2751 of Act No. 2711 and sentenced to a fine plus imprisonment. On appeal, he challenged the applicability of Act No. 1732's subsidiary imprisonment provisions to crimes created by different legislative bodies, and the proper calculation of subsidiary imprisonment. The Supreme Court held that Act No. 1732 applies to all crimes regardless of which legislative body created them, as changes in legislative personnel do not affect law applicability across periods. However, the Court found error in calculating subsidiary imprisonment, ruling that when both fine and imprisonment are imposed, subsidiary imprisonment cannot exceed one-third of the imprisonment term. The sentence was modified to reduce subsidiary imprisonment from an unspecified period to five days, being one-third of the fifteen-day imprisonment term imposed.