Title
Alonto vs. Enrile
Case
G.R. No. 54095
Decision Date
Jul 25, 1980
Muslim youth arrested in 1979 for peaceable assembly; sole detainee Alonto, Jr. released in 1980, rendering habeas corpus petition moot.
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Case Digest (G.R. No. 54095)

Facts:

    Background of the Case

    • Ahmad Domocao Alonto, Jr., a fellowship grantee pursuing postgraduate studies at the University of the Philippines, Los Baños in Community Development, was the petitioner.
    • On November 30, 1979, he was among 180 Muslim youths gathered at Luneta (Quirino Grandstand in Rizal Park, Manila) to discuss matters of common interest affecting Islamic followers and government policies.
    • The assembly, though peaceful, became the subject of government scrutiny.

    Arrest and Detention

    • Military personnel, acting under the instructions of the respondent Minister of National Defense, arrested the assembled youths.
    • The detainees, including Alonto, were taken into custody and confined at Camp Bagong Diwa in Bicutan, Taguig, Rizal.
    • At the time of arrest, none of the individuals, including Alonto, were under investigation, indicted, or charged with any offense.

    Government Justification and Subsequent Developments

    • Respondents contended that the arrest and detention were based on the allegation that Alonto and the others had participated in an illegal assembly and demonstration without securing the necessary permit.
    • It was further alleged that the demonstration was intended to show support for the Iranian stance against U.S. President Jimmy Carter.
    • A Commitment Order dated December 1, 1979, issued by Lt. Col. Julian A. Alzaga, indicated that the detained had committed the crime of illegal assembly.
    • Subsequent actions saw the release of 155 detainees on December 15, 1979, followed by the release of 24 more, leaving Alonto as the sole detainee from that gathering.
    • Notably, even after 203 days, no formal charges, investigations, or indictments were instituted against Alonto.
    • The petition for the writ of habeas corpus was eventually filed on June 23, 1980.

    Judicial and Executive Interventions

    • The petition sought relief from what was claimed to be an arbitrary detention without any charge.
    • Court hearings were expedited despite procedural delays (with sessions held on June 26, 1980, and arguments on July 3, 1980).
    • On July 11, 1980, upon presidential intervention, Alonto was temporarily released and entrusted to the custody of his brother, Albert Alonto.
    • The Solicitor General later manifested that the temporary release rendered the petition moot and academic.

Issue:

    Legality of Extended Detention

    • Whether the detention of Ahmad Alonto, Jr. for an extended period (over 203 days) without any pending charges or indictment violated constitutional protections against arbitrary detention.

    Nature of the Detention Order

    • Whether the use of an arrest, search, and seizure order (ASSO) under military custody, in the absence of criminal charges, justified continued detention.

    Scope of the Alleged Offense

    • Whether participation in a purportedly “illegal assembly” (a gathering for peaceful discussion on matters affecting Muslim youths) can constitute a crime warranting detention, particularly when the gathering involved free expression and the exercise of constitutional rights.

    Mootness Due to Executive Action

    • Whether the petition for habeas corpus should be dismissed as moot and academic in light of the President’s order for the temporary release of the petitioner.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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