GR 1430; (August, 1903) (Digest)
G.R. No. 1430 : August 12, 1903
PLACIDO BANAYO, petitioner-appellant, vs. THE MUNICIPAL PRESIDENT OF SAN PABLO, respondent-appellee.
FACTS:
On June 24, 1903, Placido Banayo filed a petition for a writ of habeas corpus before the Court of First Instance. He alleged that he was imprisoned by Municipal President Marcos Paulino of San Pablo, Laguna, since May 30, 1903, without initially being informed of the cause. He was later charged with estafa (for refusing to pay a servant’s wages) before the justice of the peace, who discharged him. Despite this discharge, the municipal president again imprisoned him. The respondent, in his return to the writ, justified the detention based on a decision dated June 6, 1903, by the Municipal Council of San Pablo. The Council found Banayo guilty of being a “disturber of the peace” (characterized as an administrative offense) for inciting litigation and cutting coconut trees on an estate, and sentenced him to 168 days of imprisonment and a fine. The Court of First Instance denied the writ, holding that Banayo was held under a valid order of a body with jurisdiction, and his remedy was by appeal. Banayo appealed to the Supreme Court.
ISSUE:
Whether the Municipal Council of San Pablo had judicial jurisdiction to try and sentence Placido Banayo for an alleged administrative offense, thereby making his detention lawful.
RULING:
No. The Supreme Court reversed the judgment of the Court of First Instance and ordered the petitioner’s discharge from custody.
The Court held that under Act No. 82 (the Municipal Code), the powers of municipal governments are clearly delineated: executive and judicial powers are vested in the municipal president, while legislative powers are vested in the municipal council. Specifically, the president is empowered to hold court for violations of public ordinances. The municipal council possesses no judicial powers whatsoever. Consequently, its proceeding against Banayo, wherein it acted as a judicial body, tried him, and imposed a penalty, was utterly void for lack of jurisdiction. The detention based on this null and void proceeding was illegal. The Court clarified that there is no such proceeding known in law as a delito gubernativo or administrative offense triable by a municipal council in a judicial manner. Since the council acted without any jurisdiction, the detention was unlawful, and habeas corpus was the proper remedy.