Title
Bartolome Caunca, in behalf of his cousin Estelita Flores y Caunca vs. Julia Salazar, owner of Far Eastern Employment Bureau
Case
G.R. No. L-2690
Decision Date
Jan 1, 1949
A young, vulnerable woman was psychologically coerced into staying with an employment agency over unpaid transportation fees, prompting a habeas corpus petition to secure her freedom.
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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:

  1. Whether the respondents, Julia Salazar and Estrella Justo, unlawfully restrained Estelita Flores of her personal liberty.
  2. Whether the respondents’ demand for repayment of P83.85 justified their interference with Estelita’s freedom of movement.
  3. 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:

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