GR L 64898; (June, 1987) (Digest)
G.R. No. L-64898. June 30, 1987.
IN THE MATTER OF THE PETITION FOR A WRIT OF HABEAS CORPUS OF NICOLAS BUENO, JR., LETICIA BUENO, petitioner, vs. PAT. MANOLO REYES and COL. ALFREDO SAN DIEGO, respondents.
FACTS
Leticia Bueno filed a petition for a writ of habeas corpus seeking the release of her husband, Nicolas Bueno, Jr. She alleged that he was illegally arrested without a warrant at their home in Pasig on August 3, 1983, at around 5:00 AM, by agents of the Mandaluyong police station. The arrest was in connection with a taxi robbery-hold-up that had occurred four days earlier, on July 29, 1983. Following his arrest, he was detained at the Mandaluyong police station jail under the custody of the respondents.
In their return to the writ, the respondents did not deny the arrest but justified the detention on multiple grounds. They stated that Nicolas Bueno, Jr. was positively identified by the victims of the July 29 robbery, leading to the filing of two criminal cases for robbery. More significantly, the respondents revealed that verification showed Bueno had a standing alias warrant of arrest for estafa (Criminal Case No. 23947) issued by Judge Celso L. Magsino as early as November 28, 1977.
ISSUE
Whether the writ of habeas corpus should be granted to order the release of Nicolas Bueno, Jr. from detention.
RULING
The Supreme Court dismissed the petition for lack of merit. The legal logic is clear: a writ of habeas corpus secures release from illegal confinement. The petition focused solely on challenging the legality of the arrest and detention for the robbery charges. However, the Court found that the detention was justified by a separate and valid legal cause—the outstanding warrant for estafa. The existence of this unexecuted warrant provided a lawful basis for his continued detention, independent of the circumstances surrounding his arrest for robbery.
Consequently, even assuming arguendo that the arrest for robbery was defective, the detention remained legal due to the pre-existing warrant. The Court cited established jurisprudence, including Pagalunan v. Station Commander and Beltran v. Garcia, which hold that detention under a valid warrant renders a habeas corpus petition unmeritorious. Since the petitioner did not challenge the validity of the estafa warrant or the detention arising from it, the Court ruled that Nicolas Bueno, Jr.’s confinement could not be deemed illegal. The writ is not available where a person is held by virtue of a lawful process or court order.