G.R. No. L-25419 June 21, 1966
ANDRES CULANAG, petitioner and appellant, vs. DIRECTOR OF PRISONS, respondent and appellee.
FACTS
Petitioner Andres Culanag was convicted of falsification of a public document by the Court of First Instance of Lanao del Norte (Criminal Case No. 671) on December 16, 1961, and sentenced to imprisonment. He was later released on parole on July 9, 1962. Subsequently, on March 31, 1964, he was charged in the Municipal Court of Mamburao, Occidental Mindoro, with another crime of falsification of a public document (Criminal Case No. 790) and, on April 3, 1964, with violation of conditional pardon under Article 159 of the Revised Penal Code (Criminal Case No. 789). Culanag filed a motion to quash these informations on the ground of double jeopardy, claiming the new falsification charge was the same offense as his prior conviction and that the violation of conditional pardon charge was included in the former offense. The municipal court denied his motion. On December 4, 1964, assisted by counsel, Culanag pleaded guilty to both charges and was convicted and sentenced accordingly. He did not appeal these decisions. The Board of Pardons and Parole also issued an order for his arrest for violating his parole conditions. Culanag filed a petition for a writ of habeas corpus in the Court of First Instance of Rizal, alleging his detention pursuant to the municipal court’s decisions was illegal due to double jeopardy. The lower court dismissed his petition, and he appealed.
ISSUE
Whether the writ of habeas corpus is the proper remedy to challenge Culanag’s detention on the ground that his convictions by the Municipal Court of Mamburao placed him in double jeopardy.
RULING
No. The Supreme Court affirmed the dismissal of the habeas corpus petition. The Court held that the remedy against any error committed by the Municipal Court of Mamburao, including a claim of double jeopardy, was an appeal from its decisions, not a writ of habeas corpus. The function of habeas corpus is to inquire into the jurisdiction of the court issuing the process and the validity of the process on its face; it is not a writ of error. A commitment based on a final judgment is conclusive evidence of the legality of detention unless the court lacked or exceeded its jurisdiction. The defense of double jeopardy does not go to the jurisdiction of the trial court but involves a judgment that, if wrongfully exercised, is mere error not reviewable via habeas corpus. The Municipal Court of Mamburao had jurisdiction over the cases, and the penalties imposed were not excessive. Therefore, Culanag’s confinement was lawful.