Title
Alejano vs. Cabuay
Case
G.R. No. 160792
Decision Date
Aug 25, 2005
Armed soldiers seized Oakwood Apartments in 2003, demanding President Arroyo's resignation. Detained officers challenged confinement conditions; Supreme Court upheld detention as lawful, deeming restrictions reasonable for security.

Case Digest (G.R. No. 160792)
Expanded Legal Reasoning Model

Facts:

  • Petition and Parties
  • Petitioners: Lawyers Homobono Adaza and Roberto Rafael Pulido, representing junior officers Capt. Gary Alejano, Capt. Nicanor Faeldon, Capt. Gerardo Gambala, Lt. SG James Layug, Capt. Milo Maestrecampo, Lt. SG Antonio Trillanes IV, and others.
  • Respondents: Gen. Pedro Cabuay (ISAFP chief, custodian), Gen. Narciso Abaya (AFP Chief of Staff), Sec. Angelo Reyes (National Defense), Sec. Roilo Golez (National Security Adviser).
  • Oakwood Incident and Detention Orders
  • On 27 July 2003, about 321 soldiers led by the junior officers seized Oakwood Premier Apartments in Makati, planted explosives, demanded President Arroyo’s resignation, and surrendered same day.
  • On 31 July and 2 August 2003, Gen. Abaya ordered the transfer of these officers to the ISAFP Detention Center; prosecutors filed coup d’état charges in Makati RTC (Crim. Case No. 03-2784), and Commitment Orders were issued.
  • Habeas Corpus Proceedings
  • Petitioners filed a habeas corpus petition in the Supreme Court on 11 August 2003; on 12 August 2003, the Court issued a writ and referred the case to the Court of Appeals for hearing and return of the writ on 18 August 2003.
  • On 17 September 2003, the Court of Appeals dismissed the petition for lack of merit but ordered Gen. Cabuay to respect detainees’ rights under SOP No. 0263-04 regarding visiting hours and exercise.
  • Supreme Court Review
  • By petition under Rule 45, petitioners sought to nullify the CA decision, alleging errors in CA’s review of the Supreme Court order, remedy appropriateness, and upholding of detention conditions.
  • On 25 August 2005, the Supreme Court affirmed the CA decision and dismissed the petition.

Issues:

  • Whether the Court of Appeals erred in reviewing and reversing a Supreme Court decision.
  • Whether the Court of Appeals erred in not recognizing the propriety of habeas corpus as a remedy for the detainees’ complaints.
  • Whether the Court of Appeals erred in upholding the legality of the conditions of detention in the ISAFP Detention Center.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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