G.R. No. 268876 - Agbayani vs. Director, Manila City Jail

Dr. Benigno A. Agbayani, Jr. was charged under an Amended Information dated June 11, 2008, for reckless imprudence resulting in serious physical injuries.
The charge stemmed from an operation he conducted on Saul Q. HofileAa, Jr.'s left knee using an allegedly unsterilized arthroscope, causing infection and serious physical injuries.
Dr. Agbayani pleaded not guilty and the case proceeded to trial before the Metropolitan Trial Court (MeTC), Branch 13.

Witnesses included Saul, his secretary Emilie Valdivia, pathologist Dr. Debbie P. Dela Fuente, Saul's wife Elizabeth, and medical technologist Christine Marie Javelona Pascual.
Documentary evidence included medical reports, affidavits, sterilization records, medical test results, and hospital logs.
Testimonies established that the instrument used in the operation was not properly sterilized, causing a bacterial infection (coagulase negative staphylococcus).

Dr. Agbayani testified he was not responsible for sterilizing or storing the instrument, relying on nurses for assurance of sterilization.
An information technician, Reynaldo Nava, testified on the unavailability of the sterilization logbook.

MeTC convicted Dr. Agbayani on July 29, 2013, sentencing him to minimum prision correccional (two years) for reckless imprudence.
Dr. Agbayani appealed to the Regional Trial Court (RTC) Manila, Branch 51.
RTC dismissed the appeal on December 23, 2013, for failure to file memorandum of appeal within the prescribed period despite extensions.
Dr. Agbayani filed multiple motions for extension; these were denied, and eventual appeal dismissal upheld.

Dr. Agbayani filed a Petition for Review before the CA, which was dismissed for procedural deficiencies, including failure to attach necessary documents.
The SC, in Resolution dated June 23, 2021, affirmed CA's decision with a modification in penalty to arresto mayor to prision correccional.
Petitioner filed motions for reconsideration which were denied, and attempts to elevate case to the SC En Banc were rejected.
The court rulings became final and executory on March 16, 2022.

MeTC, Branch 13 issued warrant of arrest dated May 24, 2023; Dr. Agbayani was detained subsequently.
Dr. Agbayani filed motions to transfer to hospital detention and to lift the warrant, which were denied.
Angeli E. Akabane, Dr. Agbayani's common-law spouse, filed a Petition for Habeas Corpus on September 8, 2023 alleging deprivation of liberty without due process and void judgment.
On October 5, 2023, Dr. Agbayani died, raising issues of mootness.

Whether the Petition for Habeas Corpus is the proper remedy to challenge the validity of Dr. Agbayani's detention.
Whether the dismissal of Dr. Agbayani's appeal by the RTC for failure to file the memorandum was lawful and whether it violated due process.
Whether the Petition for Habeas Corpus was properly filed respecting the principle of hierarchy of courts.
Whether the death of Dr. Agbayani renders the petition moot and academic.