GR L 1153; (June, 1947) (Digest)
G.R. No. L-1153; June 30, 1947
CRISPULO TALABON, petitioner, vs. THE ILOILO PROVINCIAL WARDEN, respondent.
FACTS
The petitioner, Crispulo Talabon, filed a petition for habeas corpus with the Court of First Instance of Iloilo, which was denied. He then filed another petition for habeas corpus directly with the Supreme Court based on substantially the same grounds. In view of an objection to the Supreme Court’s original jurisdiction due to the pending appeal, his attorney moved to treat the Supreme Court petition as an appeal from the lower court’s decision. The petitioner is detained under a warrant of commitment issued by the Judge of the Court of First Instance of Iloilo, sentencing him to an indeterminate penalty of 12 to 20 years of reclusion temporal for murder. The grounds for his petition are that he has been confined since 1942, was subjected to a “fantastic trial,” is continually imprisoned without a promulgated decision, and is deprived of his right to appeal because the judgment convicting him was rendered verbally by the trial judge without written findings of fact.
ISSUE
The sole question is whether the court that convicted the petitioner had jurisdiction over his person and the offense, and to impose the penalty, such that habeas corpus will not lie for alleged errors or defects in the judgment.
RULING
The Supreme Court affirmed the denial of the petition for habeas corpus. The writ of habeas corpus is a collateral attack on a judgment and lies only where the judgment is absolutely void for lack of jurisdiction. It does not lie for mere errors, irregularities, or defects. The lower court had jurisdiction over the petitioner, the offense of murder, and the authority to impose the penalty. The fact that the judgment was rendered verbally without written findings of fact, allegedly in violation of Section 2, Rule 116 of the Rules of Court and Section 12, Article VIII of the Constitution , does not render the judgment void or divest the court of its jurisdiction. Noncompliance with the requirement for a written decision with findings of fact refers to the form of the judgment, not its substance or the court’s jurisdiction. Therefore, the petitioner’s detention under a valid warrant of commitment issued by a court with jurisdiction is lawful, and habeas corpus is not the proper remedy.