G.R. No. 215585 & 215768. September 08, 2020.
IN THE MATTER OF THE PETITION FOR WRIT OF HABEAS CORPUS/DATA AND AMPARO IN FAVOR OF AMIN IMAM BORATONG, ET AL., PETITIONERS, VS. HON. LEILA M. DE LIMA, ET AL., RESPONDENTS. ANTHONY R. BOMBEO, ON BEHALF OF HERBERT R. COLANGCO, PETITIONER, VS. HON. LEILA M. DE LIMA, ET AL., RESPONDENTS.

FACTS

Petitions for Writs of Amparo and Habeas Corpus/Data were filed by and on behalf of several high-profile inmates of the New Bilibid Prison (NBP). The petitions assailed their sudden transfer on December 15, 2014, from their NBP quarters to a temporary facility at the National Bureau of Investigation (NBI) in Manila. This transfer was effected pursuant to a “SECRET” Memorandum from then Secretary of Justice Leila M. De Lima, which directed the Bureau of Corrections and the NBI to move the inmates to allow a search of their living quarters. The raid was based on intelligence reports that the inmates were conducting illegal activities, including a narcotics trade, using contraband communication devices from within the prison. The subsequent search yielded massive amounts of cash, illegal drugs, firearms, and other prohibited items.
The inmates argued that their transfer constituted an illegal and arbitrary deprivation of liberty, violating their rights. They contended that the transfer was not a valid exercise of prison administration but a pretext for an unlawful search and seizure. They further claimed the conditions and purpose of their detention at the NBI facility warranted the protective writs of Amparo and Habeas Data, alleging threats to their liberty and privacy rights.

ISSUE

Whether the petitions for Writs of Amparo and Habeas Corpus/Data have been rendered moot and academic.

RULING

Yes, the petitions are moot and academic. The Court emphasized that a case becomes moot when subsequent events render it impossible to grant any substantial relief. At the time of the Court’s decision, the inmates had long been returned to the NBP from the temporary NBI facility. The specific act complained of—their temporary detention at the NBI for the purpose of the raid—had already been terminated. Consequently, a writ of habeas corpus, which serves to inquire into the legality of present detention, could no longer be issued as they were no longer detained at the NBI. The primary relief sought was therefore incapable of being granted.
The Court also found the petitions for Amparo and Habeas Data unmeritorious. The Writ of Amparo is a remedy against unlawful acts or omissions by public authorities that violate the right to life, liberty, or security. The inmates failed to substantiate any continuing threat to their liberty or security beyond the completed transfer. The Writ of Habeas Data is designed to protect a person’s right to privacy concerning personal information, particularly when such data is collected unlawfully. The petitioners did not demonstrate any ongoing violation of this right or an actual or threatened misuse of their personal information collected during the operation. The transfer and search were executed pursuant to the State’s legitimate penal administration and duty to secure its correctional facilities from illegal activities, as provided under Republic Act No. 10575 (The Bureau of Corrections Act of 2013). The petitions were dismissed.