GR L 54761; (November, 1985) (Digest)
G.R. No. L-54761 November 13, 1985
IN RE: PETITION FOR HABEAS CORPUS OF MANUEL M. VILLAR, ERROL ORGAYA and MIGUEL QUEBEDO, petitioners, vs. JOLLY R. BUGARIN, as Director, National Bureau of Investigation; THE CHIEF, PHILIPPINE CONSTABULARY; and THE HONORABLE MINISTER OF NATIONAL DEFENSE, respondents.
FACTS
The petitioners, officers of Abba Holdings Corporation and related rural banks, were subjects of an Arrest, Search and Seizure Order (ASSO) issued on March 10, 1980, pursuant to a Presidential approval, for their alleged involvement in a large-scale swindling scheme involving “ghost borrowers” and fraudulent rediscounts from the Central Bank. Upon learning of the ASSO, they voluntarily surrendered and were detained. They filed a petition for habeas corpus on August 30, 1980. During the pendency of the petition, they were temporarily released on October 30, 1980, pursuant to orders from the AFP Chief of Staff.
Subsequent developments revealed that multiple criminal cases for estafa had been filed against the petitioners in various courts. While the habeas corpus petition was pending, the legal status of each petitioner diverged. Petitioner Miguel Quebedo was arrested on a new warrant. Petitioner Errol Orgaya remained at large. Most critically, petitioner Manuel Villar was taken back into NBI custody in Naga City by 1985 due to the court’s disapproval of his property bond in specific criminal cases (Criminal Case Nos. IR-1956 to IR-1963) pending before the Regional Trial Court in Iriga City.
ISSUE
The primary issue is whether the writ of habeas corpus remains a proper remedy to secure the release of the petitioners given the subsequent filing of multiple criminal cases against them and their varying custodial statuses.
RULING
The Supreme Court dismissed the petition. The legal logic is grounded on the fundamental purpose and limitation of the writ of habeas corpus. The writ is designed to inquire into the legality of a person’s detention at the time of the inquiry, not to adjudicate guilt or innocence. The Court found that the factual premise for the petition had been superseded by judicial processes. The petitioners’ detention was no longer solely by virtue of the executive-issued ASSO but was now anchored on formal criminal complaints filed in courts of law.
For petitioner Manuel Villar, his confinement was directly attributable to a valid court order remanding him to custody after the denial of his bail application—a judicial act. For petitioner Miguel Quebedo, his arrest was based on a judicial warrant. Petitioner Errol Orgaya was not under any form of detention. Consequently, the restraint on Villar and Quebedo was under the authority of the judiciary, placing it beyond the scope of habeas corpus, which cannot be used to challenge a detention ordered by a court of competent jurisdiction. The proper remedy for any grievance regarding their custody, such as the denial of bail, was through the judicial proceedings themselves or the appropriate appellate remedies within those cases, not a collateral attack via habeas corpus.