Facts:

Evelyn B. Bala filed a verified petition on December 6, 1977, seeking a writ of habeas corpus for her husband, Manuel V. Bala, who was detained at the M2 Metrocom detention facility of the Philippine Constabulary without lawful cause. The Chief Justice issued the writ on December 7, 1977. The respondents, which included General Fidel Ramos, Brigadier General Prospero A. Olivas, Colonel Rolando Abadilla, and Colonel Thelmo Cunanan, submitted a return stating that Manuel V. Bala, together with Cesar Diaz, was arrested based on an Arrest, Search and Seizure Order (ASSO) dated October 26, 1977, issued by the Secretary of National Defense. They claimed that Brigadier General Olivas, through Captain Rafael I. Jayme, issued a commitment order on October 28, 1977, for Bala's detention for the offense of falsifying public documents and undermining national security. The arrest and detention were allegedly justified under sections 3 and 4

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Facts:

Petition and Allegation

• Evelyn B. Bala filed a verified petition on December 6, 1977, alleging that her husband, Manuel V. Bala, was detained at the detention room of M2 Metrocom, Philippine Constabulary without lawful cause.
• The petition sought the issuance of a writ of habeas corpus for the release of Manuel V. Bala.
• On December 7, 1977, the Chief Justice issued the writ of habeas corpus.

Basis for Arrest and Detention

• The respondents contended that Manuel V. Bala, along with Cesar Diaz, was arrested pursuant to an Arrest, Search and Seizure Order (ASSO) dated October 26, 1977, which was issued by the Secretary of National Defense.
• On October 28, 1977, Brigadier General Prospero A. Olivas, in his capacity as head of the Philippine Constabulary Metropolitan Command (Metrocom), through Captain Rafael I. Jayme of the Judge Advocate General Service, issued a commitment order for Bala’s detention.
• The detention was justified on grounds that Bala was allegedly involved in falsification of official or public documents, an offense connected with undermining national security or public order.

Notification and Investigation

• It was asserted by the respondents that Manuel V. Bala was informed of the reasons for his arrest and subsequent detention.
• He was reportedly investigated for involvement in the fabrication of fake passports.
• The justification for the arrest and detention was purportedly supported by provisions under sections 3 and 4 of General Order No. 60 and section 9(a)(2) of Letter of Instructions No. 621.

Subsequent Developments and Hearing

• The matter was heard on December 14, 1977.
• On January 3, 1977 (as per the record, though contextually it reflects developments leading into early 1978), the respondents, through the Solicitor General, filed a manifestation stating that Lieutenant Colonel Thelmo Cunanan, a special assistant to the Secretary of National Defense and Chief of the National Defense Intelligence Office, had ordered the temporary release of Manuel V. Bala on December 30, 1977.
• Shortly thereafter on January 6, 1978, the petitioner withdrew her petition.
• Consequently, the case was dismissed and considered closed without costs.

Issue:

Question of Unlawful Detention

• Whether Manuel V. Bala’s detention violated his right to habeas corpus.
• Whether proper legal procedures were adhered to at the time of his arrest and detention.

Legitimacy of the Arrest and Commitment Orders

• Whether the issuance of the Arrest, Search and Seizure Order by the Secretary of National Defense and the subsequent commitment order by Brigadier General Olivas were legally justified.
• Whether due process rights were observed in the issuance and execution of these orders.

Mootness of the Petition

• Whether the order for temporary release and the petitioner’s subsequent withdrawal rendered the original petition moot and academic.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)