G.R. No. L-54095. July 25, 1980.
AHMAD DOMOCAO ALONTO, petitioner, vs. JUAN PONCE ENRILE, Minister of National Defense, CARMELO BARBERO, Chief, Office of Detainee Affairs (ODA), and CAMP COMMANDER, Camp Bagong Diwa, Bicutan Taguig, Rizal, respondents.

FACTS

Petitioner Ahmad Alonto, Jr. was among 180 Muslim youths arrested on November 30, 1979, while assembled at the Luneta in Manila. The military, acting under respondent Minister of National Defense Juan Ponce Enrile, arrested the group for allegedly holding an illegal assembly and demonstration without a permit, purportedly to express support for Iranians opposing U.S. President Jimmy Carter. Alonto was detained at Camp Bagong Diwa pursuant to a Commitment Order and later an Arrest, Search and Seizure Order (ASSO) issued by the Minister. By December 15, 1979, 179 other detainees had been released on humanitarian grounds, leaving Alonto as the sole remaining detainee from the incident. No formal charges were filed against him during his over 200-day detention. His petition for a writ of habeas corpus was filed on June 23, 1980.

ISSUE

Whether the petition for a writ of habeas corpus had been rendered moot and academic by the petitioner’s temporary release from detention during the pendency of the proceedings.

RULING

Yes, the petition was dismissed for being moot and academic. The Supreme Court, after issuing the writ and setting a hearing, received a Manifestation from the Solicitor General stating that upon orders of the President, petitioner Ahmad Alonto, Jr. had been temporarily released from detention on July 11, 1980, and entrusted to the custody of his brother. This development effectively resolved the core objective of the habeas corpus petition, which was to secure the petitioner’s release from confinement. The legal logic is grounded in the principle that courts will not adjudicate cases where there is no longer an actual, live controversy between the parties. A habeas corpus proceeding becomes functus officio when the body of the person alleged to be unlawfully restrained is produced and they are freed from custody. The release, even if temporary, removed the restraint on liberty that formed the basis for the petition. The Court noted with approval the Executive’s expeditious action in ordering the release once the situation was brought to the President’s attention, highlighting the enduring value of the writ of habeas corpus as a remedy. While the case was dismissed on mootness grounds, the Court took the opportunity to underscore the importance of according serious consideration to constitutional rights like peaceable assembly and the desirability of resorting to civil judicial processes over military detention in such matters.