Case Digest (G.R. No. L-2690)
Facts:
The case involves Bartolome Caunca, who filed a petition on behalf of his cousin, Estelita Flores y Caunca, against Julia Salazar, the owner of the Far Eastern Employment Bureau, and Estrella de Justo, a maid recruiter. Estelita, a 21-year-old orphan from Buruanga, Capiz, was brought to Manila by Estrella Justo on December 24, 1948. She was taken to the residence of Julia Salazar at 1343 Felix Huertas St., where the employment agency operated. On December 26, 1948, Bartolome visited Estelita and found her eager to leave with him. However, Julia Salazar and Estrella Justo prevented her from doing so, demanding that she first repay the amount of P83.85, which had been advanced for her fare and other expenses. Although no physical force was used to restrain Estelita, she was unable to leave due to the respondents' opposition and the presence of others in the house. Bartolome testified that Estelita, who was timid and illiterate, was emotionally distressed and unable to asser...
Case Digest (G.R. No. L-2690)
Facts:
Background of the Case:
- Estelita Flores, a 21-year-old orphan, illiterate and from Buruanga, Capiz, was brought to Manila by Estrella Justo, a maid recruiter, on December 24, 1948.
- She stayed at the house of Julia Salazar, owner of the Far Eastern Employment Bureau, located at 1343 Felix Huertas St., Manila.
Incident Leading to the Petition:
- On December 26, 1948, Bartolome Caunca, Estelita’s cousin, visited her. Estelita expressed her desire to leave with him but was prevented by Julia Salazar and Estrella Justo.
- The respondents demanded that the sum of P83.85, advanced for Estelita’s transportation expenses from Buruanga to Manila, be paid before she could leave.
Psychological and Social Context:
- Estelita was described as timid, undernourished, and of low mentality. She was unable to assert herself due to her crass ignorance and pusillanimous character.
- Despite no physical force being used, the psychological and moral compulsion exerted by the respondents, particularly Julia Salazar, effectively deprived Estelita of her freedom of movement.
Legal Action Taken:
- Bartolome Caunca filed a petition for a writ of habeas corpus on December 31, 1948, seeking Estelita’s release.
- The writ was issued immediately, and a hearing was set for the same day. However, Julia Salazar failed to produce Estelita, claiming she had taken her to Silang, Cavite.
- After multiple hearings, the court found that Estelita was indeed restrained of her personal liberty, even in the absence of physical force.
Issue:
- Whether the respondents, Julia Salazar and Estrella Justo, unlawfully restrained Estelita Flores of her personal liberty.
- Whether the respondents’ demand for repayment of P83.85 justified their interference with Estelita’s freedom of movement.
- Whether psychological or moral compulsion, in the absence of physical force, constitutes a deprivation of liberty warranting judicial intervention.
Ruling:
The court ruled in favor of the petitioner, Bartolome Caunca, and granted the writ of habeas corpus. The court ordered that Estelita Flores be allowed to go with her cousin or to any place of her choice, free from any interference by the respondents. The decision was to be executed immediately upon its promulgation on January 1, 1949.
Ratio:
- (Unlock)