G.R. No. 1251 : March 27, 1903
FRANK MEKIN, petitioner-appellee, vs. GEORGE N. WOLFE, Warden of Bilibid Prison, respondent-appellant.

FACTS:
Frank Mekin, a former member of the Thirty-seventh Infantry, U.S. Volunteers, was discharged in February 1901. On July 13, 1901, a military commission tried, convicted, and sentenced him to twenty years of hard labor for entering the service of the enemy in violation of the laws of war. The sentence was approved on September 23, 1901, and later commuted to imprisonment at hard labor for twenty years, with the commutation and order of confinement published in General Orders on November 30, 1901. Mekin filed a petition for a writ of habeas corpus before the Court of First Instance, arguing that the military commission lacked jurisdiction over his person and the offense, as he was a civilian at the time of trial, and that he was entitled to the benefits of the amnesty proclamation issued by the U.S. President on July 4, 1902. The Warden, George N. Wolfe, justified the detention under the authority of the U.S. commanding general in the Philippines, citing the military commission’s sentence. The trial court granted the writ and ordered Mekin’s discharge upon taking an oath of allegiance, prompting the government’s appeal.

ISSUE:
Whether the Court of First Instance had the authority to grant the writ of habeas corpus and order Mekin’s discharge, considering the certificate issued by the commanding general under Act No. 272 of the Philippine Commission.

RULING:
The Supreme Court reversed the decision of the Court of First Instance and ordered Mekin remanded to custody. The Court held that Act No. 272, enacted on October 21, 1901, governed the proceedings. Under this Act, a certificate from the commanding general stating that a prisoner is held either (1) as one committed by a military court or commission prior to October 1, 1901, or (2) as one arrested and held for trial before October 15, 1901, for a violation of the laws of war committed before that date, constitutes a conclusive answer to a writ of habeas corpus. The certificate submitted by Major-General George W. Davis strictly complied with these provisions, as it certified that Mekin was held under a sentence from a military commission prior to October 1, 1901, and was arrested for a violation of the laws of war committed before October 15, 1901. Consequently, upon the presentation of this certificate, the court’s power to inquire further or discharge the prisoner ceased. The Court found it unnecessary to address other issues, such as the jurisdiction of the military commission or the applicability of the amnesty proclamation, given the conclusive nature of the commanding general’s certificate under the law.