G.R. No. 33167 , November 18, 1930
ROSAIDA QUINTOS, petitioner-appellant, vs. THE DIRECTOR OF PRISONS, respondent-appellee.

FACTS

Rosaida Quintos, the mother of Joseph L. Wilson, filed a petition for habeas corpus in the Court of First Instance of Manila, alleging that her son was illegally imprisoned. Wilson had been convicted in four separate cases in the trial court. He appealed all four convictions to the Supreme Court. While the appeals were pending, Wilson fled the jurisdiction. Consequently, upon motion of the Attorney-General, the Supreme Court dismissed his appeals and declared the judgments final. Wilson was then committed to Bilibid Prison to serve his sentences. In his appeal to the Supreme Court, Wilson had raised an assigned error (the twenty-second) arguing that the facts alleged in three of the complaints constituted only one crime, and thus his convictions for three separate offenses violated the constitutional prohibition against double jeopardy. This specific issue was never ruled upon by the Supreme Court due to the dismissal of his appeals. The habeas corpus petition sought to challenge his detention on this double jeopardy ground.

ISSUE

Whether a writ of habeas corpus is the proper remedy to raise a claim of double jeopardy after final judgments of conviction have been rendered.

RULING

No. The Supreme Court denied the petition and affirmed the trial court’s refusal to grant the writ of habeas corpus. The Court held that the function of habeas corpus is limited to inquiring into the jurisdiction of the court that issued the commitment and the validity of the process on its face. It is not a writ of error to correct mere errors of judgment. A commitment based on a final judgment of conviction is conclusive evidence of the legality of detention, unless the court that rendered the judgment was without or exceeded its jurisdiction. The defense of double jeopardy does not go to the jurisdiction of the trial court; it is a defense that must be pleaded at arraignment. If erroneously disregarded by the trial court, it constitutes an error of judgment, not a jurisdictional flaw, and is therefore not reviewable via habeas corpus. The attempt to raise the double jeopardy issue through habeas corpus was an impermissible indirect effort to obtain a ruling on a question that was not addressed due to the dismissal of his direct appeal.