Case Digest (G.R. No. L-14819)
Facts:
Alfredo B. Saulo v. Brig. Gen. Pelagio Cruz, G.R. No. L-14819, March 19, 1959, the Supreme Court, Concepcion, J., writing for the Court. Petitioner Alfredo B. Saulo filed a petition for a writ of habeas corpus alleging illegal detention and seeking his discharge. Upon filing, the Court issued a resolution dated December 24, 1958 directing respondent Brig. Gen. Pelagio Cruz, Commanding General of the Philippine Constabulary, to file an answer returnable to the Court of First Instance (CFI) of Manila.On January 14, 1959 the CFI of Manila entered an order observing that the material facts in the petition (except the legal conclusion of illegality) were substantially admitted in respondent's answer and stating that respondent questioned the CFI's jurisdiction under Rule 102, Sec. 2 of the Rules of Court to decide the issues presented. The CFI framed two legal questions (concerning arrest without warrant where the statute requires a preliminary investigation, and release during the preliminary investigation) but, without finally passing on the jurisdictional issue, directed that the record, transcript of proceedings, and memoranda be forwarded to the Supreme Court for further action.
The Supreme Court then considered whether a writ of habeas corpus issued by the Supreme Court and made returnable to a CFI confers jurisdiction on that CFI to hear and finally determine the habeas petition, and whether the CFI was the proper forum to adjudicate the subst...(Pro-only)
Issues:
- Whether the Court of First Instance of Manila may validly inquire into and finally decide the habeas corpus petition made returnable to it after the writ was issued by the Supreme Court (i.e., whether the CFI has jurisdiction to hear the case).
- Whether a person arrested without warrant for an alleged violation of an Act that expressly requires a preliminary investigation (here, the Anti-Subversion Act, R.A. No. 1700) may be detained without warrant and whether such person is entitled to release durin...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)