G.R. No. 176653. April 2, 2007.
IN THE MATTER OF THE APPLICATION FOR ISSUANCE OF WRIT OF HABEAS CORPUS IN BEHALF OF LETICIA LOURDES A. CAMARA, ASST. VICE PRESIDENT OF LAND BANK OF THE PHILIPPINES, REPRESENTED BY HER SON, MARK DARWIN CAMARA, Petitioner, vs. HON. ERNESTO P. PAGAYATAN, IN HIS CAPACITY AS PRESIDING JUDGE, RTC SAN JOSE, OCCIDENTAL MINDORO, BRANCH 46, AND ALL OTHER PERSONS ACTING ON HIS BEHALF, Respondents.

FACTS

Leticia Lourdes A. Camara, an Assistant Vice-President of the Land Bank of the Philippines (LBP), was cited for indirect contempt and ordered arrested by respondent Judge Ernesto Pagayatan for LBP’s alleged failure to comply with a March 4, 2005 Order directing the deposit of preliminary compensation in an agrarian case. The arrest warrant was issued on February 9, 2007, and Camara was detained on February 12, 2007. On February 14, 2007, LBP filed a Compliance, depositing the full amount in cash and bonds with its head office in Manila under an account “in trust for” the Clerk of Court. Following a hearing, the trial court on February 21, 2007, found the compliance insufficient, demanding the deposit be made directly payable to the private claimant, Josefina Lubrica, in a readily withdrawable form, and refused to release Camara.

ISSUE

Whether the continued detention of Camara after LBP’s deposit of the mandated amount constituted a grave abuse of discretion, making the writ of habeas corpus proper despite the initial validity of the contempt order.

RULING

Yes. The Supreme Court granted the petition and made the writ of habeas corpus permanent. While a writ of habeas corpus generally does not lie when detention is under a valid court process, the office of the writ is to inquire into the legality of the continued deprivation of liberty. Here, the legal basis for Camara’s detention was her disobedience of the March 4, 2005 Order. The core directive of that Order was for LBP to deposit the specified amount with the Land Bank in Manila. LBP fulfilled this directive by making the deposit on February 14, 2007. The subsequent orders by respondent judge, which imposed additional requirements such as making the deposit immediately withdrawable by the private claimant, constituted new directives not found in the original order. Once the act required by the contempt order—the deposit—was performed, the justification for continued detention ceased. The respondent judge’s refusal to release Camara after compliance was a capricious and whimsical exercise of power, amounting to grave abuse of discretion. Her detention thus became illegal, warranting the relief afforded by the writ of habeas corpus.