GR 138268; (May, 1999) (Digest)
G.R. No. 138268. May 26, 1999. JURRY ANDAL, RICARDO ANDAL and EDWIN MENDOZA, petitioners, vs. PEOPLE OF THE PHILIPPINES, REGIONAL TRIAL COURT, BATANGAS BR. 05, LEMERY, THE DIRECTOR, BUREAU OF CORRECTIONS, and THE HONORABLE, THE SECRETARY OF JUSTICE, respondents.
FACTS
Petitioners Jurry Andal, Ricardo Andal, and Edwin Mendoza, convicted of rape with homicide and sentenced to death, filed a petition for a writ of habeas corpus to challenge the legality of their detention and to stay their scheduled execution. They argued that the trial court was ousted of jurisdiction due to an alleged deprivation of their constitutional rights, specifically claiming that their pre-trial identification was conducted without the assistance of counsel and without a valid waiver. They invoked a separate opinion in Olaguer v. Military Commission No. 34 suggesting that a proven constitutional violation renders a judgment void, making habeas corpus the proper remedy.
ISSUE
Whether the writ of habeas corpus is the appropriate remedy to assail the petitioners’ conviction and death sentence based on alleged violations of their constitutional rights during the pre-trial identification process.
RULING
The Supreme Court DENIED the petition. The Court acknowledged that habeas corpus extends to cases of illegal confinement due to a deprivation of constitutional rights, a lack of jurisdiction by the sentencing court, or an imposed excessive penalty. However, it found no such constitutional violation in this case. The Court ruled that the alleged infirmity in the pre-trial identification did not affect the validity of the trial or the judgment. As held in its prior decision affirming the conviction, any irregularity in the arrest was cured when the petitioners voluntarily submitted to the court’s jurisdiction by entering their plea. The evidence, including the positive identification by a prosecution witness, was sufficient to support the conviction. The Court characterized the petition as a disguised second motion for reconsideration of a final judgment, noting that the accused were afforded every opportunity in a fair trial by a court of competent jurisdiction. The imposition of the death penalty was affirmed as the correct penalty prescribed by law for the crime of rape with homicide.