G.R. No. and Date: G.R. Nos. L-9619 and L-9620; March 28, 1914

FACTS:
The petitioners were convicted by the Court of First Instance of Manila for violating Section 3 of Ordinance No. 152 of the City of Manila, which prohibits visiting or being present in any place where opium is smoked or unlawfully dealt with. They were each sentenced to pay a fine of P100, with subsidiary imprisonment in case of nonpayment. The conviction was based on evidence that police officers found opium-smoking utensils, a strong odor of opium fumes, and a warm opium pipe in a room of a house (a Chinese club) where all petitioners were present. The trial court, in its decision, explicitly noted there was no proof that the house was “destined or habitually used as a place for the smoking of opium.” The petitioners filed applications for writs of habeas corpus, arguing that their convictions were null and void because (1) there was no evidence to support the judgment, and (2) the trial court’s own findings showed they were not guilty of violating the ordinance as interpreted in a prior Supreme Court decision (United States vs. Ten Yu). Subsequently, they also sought to amend their petition to argue that the court lacked jurisdiction because the criminal case was improperly entitled in the name of the “City of Manila” instead of the “United States.”

ISSUE:
1. Whether a writ of habeas corpus is proper to release the petitioners on the grounds that the judgment of conviction is void due to a lack of evidence and because the trial court’s findings allegedly negate the essential elements of the crime.
2. Whether a writ of habeas corpus is proper to release the petitioners on the ground that the court lacked jurisdiction because the criminal case was filed in the name of the “City of Manila” instead of the “United States.”

RULING:
The Supreme Court DENIED the applications for the writs of habeas corpus.

1. On the Validity of the Conviction Based on the Evidence and Findings: The Court held that the writ of habeas corpus was not available. The trial court had jurisdiction over the persons of the petitioners and the subject matter (a violation of Ordinance No. 152). The determination of whether the facts proven constituted the crime defined by the ordinance was a judicial function within the court’s jurisdiction. Even if the conviction was allegedly erroneous or based on insufficient evidence, it was not a void judgment but merely an erroneous one. Habeas corpus cannot be used to correct errors of law or fact committed by a court acting within its jurisdiction. The petitioners’ remedy was an appeal, not a collateral attack via habeas corpus.

Costs were declared de officio.