GR 167211; (March, 2006) (Digest)
G.R. No. 167211 , March 14, 2006
IN THE MATTER OF THE PETITION FOR THE HABEAS CORPUS OF ATTY. FERNANDO ARGUELLES, JR., ET AL., Petitioners, vs. MAJ. GEN. JOSE BALAJADIA, JR., Respondent.
FACTS
The Senate Committee on Banks scheduled a hearing to investigate the Standard Chartered Bank. The bank filed a petition for prohibition with the Supreme Court to stop the inquiry. During the hearing, the bank’s counsel provided the Committee a copy of this petition, which contained an allegation that the investigation was conducted “in aid of collection” rather than legislation, a statement Senator Enrile found cast a slur on the Committee. The bank’s CEO, Paul Simon Morris, verified the allegation upon advice of counsel. Senator Enrile moved to cite the bank officers and their counsel, Attys. Arguelles and Geronimo, for contempt. The Committee Chair, Senator Angara, then issued an Order directing the Senate Sergeant-at-Arms, Maj. Gen. Jose Balajadia, Jr., to detain them for direct contempt for not more than six hours.
The detained individuals immediately filed a petition for habeas corpus, arguing the contempt citation was unconstitutional and void for reasons including that the alleged contemptuous act occurred outside the proceedings, the petition’s allegations were privileged, and they were denied due process. They were released later that same day. Subsequently, the bank officers moved to be excluded from the case, which was granted, leaving only the two lawyers as petitioners pursuing the resolution of the constitutional issues.
ISSUE
Whether the Supreme Court should resolve the constitutional issues raised in the habeas corpus petition despite the petitioners’ release from detention.
RULING
The Supreme Court dismissed the petition for being moot. The Court explained that the essential object of a writ of habeas corpus is to inquire into the legality of a person’s involuntary restraint and to secure their release if such restraint is illegal. Since petitioners had already been released from the custody of the Senate Sergeant-at-Arms, the primary relief sought—their liberty—had already been attained. Consequently, the petition was rendered moot.
While the Court acknowledged the importance and transcendental nature of the constitutional issues raised concerning congressional contempt powers and human rights, it declined to rule on them in this proceeding. The Court emphasized it was not appropriate to do so, particularly because the Senate Committee itself, which issued the contempt order, was not made a party-respondent in the case. Only the Sergeant-at-Arms, who merely executed the Committee’s order, was impleaded. Thus, the Committee was not given an opportunity to be heard on the substantive allegations against its actions. The dismissal was strictly based on the mootness of the habeas corpus petition.