GR 153795; (August, 2006) (Digest)
G.R. No. 153795 August 17, 2006
MA. ESTRELITA D. MARTINEZ, Petitioner, vs. Director General LEANDRO MENDOZA, et al., Respondents.
FACTS
Petitioner Ma. Estrelita D. Martinez, mother of Michael Martinez, filed a petition for habeas corpus. She alleged that Michael was abducted on November 19, 2001. The petition was filed against high-ranking PNP-CIDG officials, claiming they had custody of Michael. This claim was primarily based on the testimony of Phillip Medel, Jr., a suspect in the Nida Blanca murder case. Medel testified that he saw Michael detained and mistreated at the CIDG office in Camp Crame on the night of the abduction or early the next morning, implicating the respondent police officials.
The respondents categorically denied any involvement in the abduction or any custody over Michael Martinez. They presented evidence, including an alibi for one official, and argued they had no motive to detain Michael, who was considered a vital witness. The Regional Trial Court granted the writ, crediting Medel’s testimony over the respondents’ denial. The Court of Appeals reversed this decision, dismissing the petition due to Medel’s lack of credibility and the presumption of regularity in the performance of official duties by the police.
ISSUE
Whether the Court of Appeals erred in reversing the trial court and dismissing the petition for a writ of habeas corpus.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The core legal principle applied is that in habeas corpus proceedings, the burden of proof rests upon the petitioner to establish by competent and convincing evidence that the person alleged to be detained is indeed under the custody of the respondent. A mere denial of custody by the respondent does not automatically warrant the issuance of the writ; the petitioner must substantiate the claim of detention.
Here, the Court found the petitioner’s evidence insufficient. The testimony of Phillip Medel, Jr. was deemed highly suspect due to inconsistencies and a lack of credibility, especially when weighed against the respondents’ persistent denials and the presumption of regularity in the performance of official duties. The Court emphasized that a writ of habeas corpus is not proper where the respondent denies custody and the petitioner fails to present decisive proof to the contrary. The writ cannot issue merely on suspicion or unsubstantiated allegations. However, noting the indubitable disappearance of Michael Martinez, the Court directed concerned law enforcement agencies to continue their investigation with due diligence to locate him and hold accountable those responsible.