G.R. No. L-44800. April 13, 1978.
MIGUEL A. ANAS, petitioner, vs. HON. JUAN PONCE ENRILE, as Secretary of National Defense, GEN. ROMEO C. ESPINO, as Chief of Staff, AFP Reviewing Authority, and MAJOR GEN. FIDEL V. RAMOS, as Chief of the Philippine Constabulary and Commander of the Command for the Administration of Detainees, respondents.

FACTS

Petitioner Miguel A. Anas filed a petition for a writ of habeas corpus on October 1, 1976, while detained at the New Bilibid Prison. His detention was pursuant to a decision by Military Commission No. 17, which convicted him of Usurpation of Authority under Article 177 of the Revised Penal Code and sentenced him under Presidential Decree No. 39. Anas challenged the military tribunal’s jurisdiction, arguing that the sentence failed to state the facts and law clearly, that his confinement preceded the finality of the sentence, that the Indeterminate Sentence Law should apply, and that an undue delay in the review of his case rendered his detention illegal.
The respondents, through the Acting Solicitor General, filed a return asserting the validity of the charge, trial, and sentence. During the hearing, respondents’ counsel committed to request the Secretary of National Defense for Anas’s transfer and temporary release pending the final review of his appeal to the President. Subsequently, the Secretary issued a memorandum on November 17, 1976, directing Anas’s immediate temporary release for humanitarian reasons.

ISSUE

The primary issue is whether the petition for habeas corpus has been rendered moot and academic by the petitioner’s release from detention.

RULING

The Supreme Court dismissed the petition for being moot and academic. The legal logic is grounded in the core principle that a writ of habeas corpus is a remedy designed to inquire into the legality of a person’s detention and to secure their release if such detention is unlawful. The very essence of the proceeding is rendered inoperative once the restraint on liberty is lifted. The Court noted that following the respondents’ manifestations, petitioner Anas had been ordered temporarily released on November 17, 1976, and was confirmed to have been left in Iloilo City by November 27, 1976, in connection with other bonded criminal cases. Since he was admittedly no longer under the detention challenged in his petition, there was no actual restraint for the court to remedy.
The Court, citing a line of jurisprudence from Tan Me Nio v. Collector of Customs to Malolos v. Ramos, consistently held that the release of the detainee deprives a habeas corpus petition of its justiciable character. The controversy becomes academic, and courts will not adjudicate matters where no substantial relief can be granted. Therefore, without a live case or active restraint to redress, the petition was properly dismissed.