GR 57069; (August, 1981) (Digest)
G.R. No. L-57069 August 31, 1981
IN THE MATTER OF THE PETITION FOR THE HABEAS CORPUS OF EDMUNDO RAMIREZ; ATTORNEY ABDON A. ARRIBA, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.
FACTS
Attorney Abdon A. Arriba filed a petition for a writ of habeas corpus on behalf of his client, Edmundo Ramirez, who had been detained for over two years and five months following the termination of his trial for attempted rape. Ramirez was unable to post bail and remained confined in the provincial jail of Misamis Oriental. The Supreme Court granted the petition and issued the writ on June 11, 1981, directing the respondent to make a return and setting the case for hearing.
In a compliance filed by the Solicitor General on July 3, 1981, it was reported that Edmundo Ramirez had already been released from detention on June 29, 1981. His release was effected by virtue of an order from Judge Tago M. Bantuas of the Court of First Instance of Misamis Oriental, who, on the same date, promulgated a decision acquitting Ramirez of the charge of attempted rape. Consequently, the Solicitor General moved for the dismissal of the petition as moot and academic.
ISSUE
Whether the petition for a writ of habeas corpus has been rendered moot and academic by the release of the detainee.
RULING
Yes, the petition is moot and academic. The primary purpose of the writ of habeas corpus is to secure the immediate liberty of an individual whose detention lacks legal justification. The Court emphasized that habeas corpus is the paramount remedy to relieve persons from unlawful restraint, serving as the best defense of personal freedom. Once the detainee is released from custody, the very object of the writ is achieved, and the petition loses its justiciable character.
In this case, the release of Edmundo Ramirez through a judicial order of acquittal terminated his unlawful detention, thereby fulfilling the purpose of the habeas corpus petition. However, the Court took note of the undue delay in the rendition of the judgment, which prolonged Ramirez’s detention despite the conclusion of his trial. While the petition was dismissed as moot, the Court required Judge Bantuas to explain within fifteen days the delay in deciding the criminal case, underscoring that the right to a speedy disposition of cases remains a vital constitutional guarantee. The writ of habeas corpus, while rendered moot by the release, validly served its function as a mechanism to compel attention to an unjustly prolonged deprivation of liberty.