G.R. No. L-60326, June 29, 1982
In the Matter of the Petition for Habeas Corpus for Jaime B. Bernal, Dr. Ramon A. Bernal, petitioner, vs. Minister Juan Ponce Enrile, General Fabian C. Ver, Brig. General Prospero Olivas, Colonel Galileo Quintanar, respondents.

FACTS

Dr. Ramon A. Bernal filed a petition for habeas corpus on behalf of his son, Jaime B. Bernal, who was arrested without a warrant on April 24, 1982, by military agents and detained at Camp Bago Bantay. The petition emphasized Jaime’s critical health condition, citing his recent confinement for a stroke and diabetes, and alleged that his continued detention without proper medical care could be life-threatening. It further asserted that Jaime had not committed any crime and was not detained by any lawful court order. The Court promptly issued the writ, requiring the respondents to make a return.
In their return, the respondents, represented by the Solicitor General, justified the detention by virtue of a Presidential Arrest and Commitment Order dated April 22, 1982, for the crime of subversion. They argued that the privilege of the writ of habeas corpus remained suspended for such offenses under Proclamation No. 2045. The return also alleged that Jaime was an active member of the Communist Party of the Philippines and its front organization, the National Democratic Front. Furthermore, it stated that upon learning of his heart ailment, military authorities had him confined at the V. Luna Medical Center for treatment and observation.

ISSUE

Whether the petition for habeas corpus had become moot and academic, thereby warranting its dismissal.

RULING

The Supreme Court dismissed the petition for being moot and academic. The legal logic proceeded from the fundamental purpose of the writ of habeas corpus as a swift remedy to relieve persons from unlawful restraint, as established in Villavicencio v. Lukban. Prior to the hearing, the petitioner filed a manifestation and motion to withdraw the petition, stating that after having seen his son and ascertained his sound health at V. Luna Medical Center, his primary concern for his son’s life and health was alleviated. He expressed his intent to instead seek his son’s release through procedures prescribed by the Ministry of National Defense.
During the hearing, the Court verified the petitioner’s voluntary and affirmative decision to withdraw, noting his admission that his son was not illegally detained. The detainee, Jaime B. Bernal, was present and concurred. Given the petitioner’s clear abandonment of the judicial remedy in favor of an executive appeal, the Court found no compelling reason to insist on adjudicating the merits. The respondents, through the Assistant Solicitor General, also assured the Court that the detainee’s rights to counsel and family visits would be respected. Consequently, with the central grievance—the alleged deprivation of medical care—being resolved and the petitioner electing an alternative course, the case was rendered moot. The dismissal was qualified by the affirmation that all constitutional rights available to a detainee must remain accessible to Jaime B. Bernal.