GR 268876; (August, 2024) (Digest)
G.R. No. 268876, August 07, 2024
Dr. Benigno A. Agbayani, Jr., Duly Represented by His Common Law Spouse, Angeli E. Akabane, Petitioner, vs. Director or Whoever is in Charge of the Manila City Jail, and All Persons Taking Orders from Him/Her, Jr. Supt. Mirasol Vocal-Vitor, City Jail Warden of Manila City Jail-Male Dormitory, Respondents.
FACTS
This is a Petition for Habeas Corpus filed by Angeli E. Akabane, the common-law spouse of Dr. Benigno A. Agbayani, Jr., seeking his release from confinement. The petition stems from a criminal conviction. Dr. Agbayani was charged with Reckless Imprudence Resulting in Serious Physical Injuries before the Metropolitan Trial Court (MeTC) of Manila, Branch 13, for allegedly using an unsterilized medical instrument (arthroscope) during an operation on complainant Saul Q. Hofileña, Jr.’s left knee on January 5, 2006. The MeTC rendered a Judgment dated July 29, 2013, finding Dr. Agbayani guilty and sentencing him to imprisonment. This judgment was upheld with modification as to penalty by the Supreme Court in a Resolution dated June 23, 2021, in G.R. No. 215121, which attained finality on March 16, 2022. The petitioner contends that Dr. Agbayani’s deprivation of liberty is based on a void judgment that has not become final and executory and was issued without due process.
ISSUE
Whether the writ of habeas corpus should be granted to order the release of Dr. Benigno A. Agbayani, Jr. from detention.
RULING
No, the writ of habeas corpus is denied. The Supreme Court held that the petition lacked merit. A writ of habeas corpus is a remedy to inquire into the legality of a person’s detention. It is not available where the person is detained by virtue of a judicial process, such as a final judgment of a competent court. The Court found that Dr. Agbayani’s confinement is pursuant to the final and executory Judgment of the MeTC, as affirmed with modification by the Supreme Court. The petitioner’s arguments essentially sought a review of the factual findings and legal conclusions of the trial court, which is not the function of a habeas corpus proceeding. Habeas corpus cannot be used as a substitute for appeal or to correct errors of judgment. Since Dr. Agbayani’s detention is under a valid and final judgment, the writ cannot be issued. The Court emphasized that the proper remedy from a judgment of conviction is an appeal, not a collateral attack via habeas corpus. The petition was dismissed for failing to establish that the detention was unlawful.