G.R. No. L-49014. April 30, 1979.
In the Matter of the Petition for Habeas Corpus in behalf of ANDERSON BELTRAN and DEMETRIO RIVERA, MARIA BELTRAN and PRUDENCIA RIVERA, petitioners, vs. P.C. CAPTAIN ROLANDO GARCIA, respondent.

FACTS

Petitioners Maria Beltran and Prudencia Rivera filed an application for a writ of habeas corpus on behalf of Anderson Beltran and Demetrio Rivera, alleging they were arbitrarily detained by PC Captain Rolando Garcia at a military stockade without any formal criminal complaint or information of charges. The Supreme Court issued the writ. In his return, the Solicitor General confirmed the apprehension and detention, stating Beltran was held for smuggling and falsification of public documents under an Arrest and Seizure Order, while Rivera had already been released. At the hearing, Rivera’s release was admitted, rendering his petition moot. For Beltran, petitioners challenged the authenticity of the arrest order and pleaded for his release due to his family’s hardship.

ISSUE

The primary issue is whether the petition for habeas corpus remains viable given the subsequent judicial commitment of Anderson Beltran.

RULING

The petition is dismissed. For Demetrio Rivera, the case is moot and academic due to his confirmed release. For Anderson Beltran, the petition has been rendered moot by supervening events. During the pendency of the habeas corpus proceeding, Beltran was formally charged in court. An information for falsification was filed with the Court of First Instance of Zambales, which issued a warrant and a commitment order directing his detention at a civilian detention center. The legal logic is clear: habeas corpus is a remedy against illegal restraint. Once a person is detained under a valid judicial order, the custody is transferred from military to civilian authority, and the detention is thereby legalized. The writ’s purpose is to inquire into the legality of detention at the time of filing. When a subsequent judicial commitment provides lawful authority for confinement, any initial defect is cured, and the petition loses its basis. The Court cited Cruz v. Montoya, which held that when the ordinary civil process is followed, the grievance ceases to exist. However, the Court admonished officials for their initial inaction, noting that constitutional rights should not require judicial prodding to be respected, as such inefficiency jeopardizes the rule of law.