G.R. No. L-41557 August 18, 1977
IN THE MATTER OF THE PETITION FOR HABEAS CORPUS OF DAVID CANAS, FLORENCIA CANAS, petitioner, vs. DIRECTOR OF THE BUREAU OF PRISONS, ET AL., respondents.

FACTS

Florencia Cañas filed a petition for a writ of habeas corpus on behalf of David Cañas, alleging his illegal detention. The petition stated that on September 4, 1975, David was taken from his home by five individuals, two of whom identified themselves as detectives from Precinct 3 in Tondo, Manila, without any warrant of arrest. He was subsequently brought to the Manila Police Headquarters and was being deprived of his liberty at the New Bilibid Prisons, in violation of his constitutional rights. The petitioner prayed for an order directing his immediate release.
In response, the Director of Prisons filed a return of the writ, asserting that David Cañas’s detention was lawful. The return indicated that on October 4, 1975, David was recommitted to the Bureau of Prisons to serve a sentence imposed under a final judgment. This was based on a decision dated February 9, 1960, from the Court of First Instance of Manila in Criminal Case No. 44521 for Murder, where he was found guilty of Homicide and sentenced to an indeterminate penalty. Accompanying the return were certified copies of the court’s commitment order and the final judgment.

ISSUE

Whether the writ of habeas corpus should be granted to secure the release of David Cañas from detention.

RULING

The Supreme Court dismissed the petition. The legal logic is anchored on the fundamental principle that a writ of habeas corpus is a remedy designed to inquire into the legality of a person’s detention. Its purpose is to secure immediate relief from unlawful imprisonment, not to correct errors of judgment or review the merits of a conviction. The writ will not issue if the detention is pursuant to a lawful order from a competent court.
In this case, the Court found that the detention of David Cañas was in execution of a final and executory judgment. The respondents presented valid and subsisting documents, including the court’s decision and the corresponding commitment order, which established a legal basis for his incarceration. Since his imprisonment was by virtue of a final judgment rendered by a court of competent jurisdiction, his detention was lawful. The circumstances of his rearrest, even if initially without a warrant, became irrelevant as he was being held under a valid commitment to serve a lawfully imposed sentence. Consequently, habeas corpus could not be invoked as the deprivation of liberty was not illegal. The Court upheld the authority of the Director of Prisons to detain the petitioner in accordance with the court’s order.