G.R. No. L-48471. September 30, 1978.
IN THE MATTER OF THE PETITION FOR THE HABEAS CORPUS OF ENGILBERTO DACUYAN, BETY A. DACUYAN, petitioner, vs. GENERAL FIDEL RAMOS, Chief, Philippine Constabulary, respondent.

FACTS

Petitioner Bety A. Dacuyan filed a habeas corpus petition for her husband, Engilberto Dacuyan, alleging he was taken from their residence on May 19, 1978, by individuals posing as agents and was detained at the PC Detention Center in Camp Crame. The petition asserted that no formal complaint or judicial order for his commitment had been issued, rendering his continuous detention illegal for lack of a specific charge. The Court issued the writ, requiring a return from respondent General Fidel Ramos.
The Return of the Writ justified the detention, stating Dacuyan was validly arrested and charged in Criminal Case No. MC25-46 before Military Commission No. 25 for illegal possession of firearm with kidnapping for ransom. Petitioner’s counsel, in his memorandum, challenged the jurisdiction of the military commission, arguing the warrant of arrest issued by its trial counsel, Major Ido A. Abdullah, was constitutionally defective. He contended that probable cause was not properly determined by a judge or authorized officer and that the accused was insufficiently identified.

ISSUE

Whether the writ of habeas corpus should be granted to release Engilberto Dacuyan from detention based on alleged defects in the military commission’s arrest warrant and jurisdiction.

RULING

The Supreme Court dismissed the petition. The legal logic proceeds from the principle that habeas corpus is unavailable if a person is lawfully detained under a valid cause. While the petition raised significant constitutional questions regarding the issuance of the military arrest warrant and the jurisdiction of the military commission—citing settled doctrine that habeas corpus lies where jurisdiction is lost due to a denial of constitutional rights—the Court found it unnecessary to resolve these issues.
The decisive factor was information subsequently provided by the respondent, revealing that Engilberto Dacuyan was also an accused in multiple criminal cases for theft before various branches of the Court of First Instance of Manila, for which standing orders of arrest had been issued. Crucially, coordination between military and civilian authorities had already resulted in Dacuyan’s physical turnover from PC custody to the Manila City Warden on July 24, 1978, pursuant to these judicial warrants. Since his detention was now anchored on valid orders from civil courts, any prior defect in the military arrest process became moot. Under Section 4, Rule 102 of the Revised Rules of Court, the writ cannot issue when the person is in custody under a lawful process or by virtue of a lawful judgment. Therefore, his continued detention was legal, and the writ was not an available remedy.