Case Digest (G.R. No. 176563)
Facts:
In the Matter of the Application for Issuance of Writ of Habeas Corpus in Behalf of Leticia Lourdes A. Camara, G.R. No. 176563, April 02, 2007, Supreme Court Second Division, Carpio, J., writing for the Court. Petitioner is Mark Darwin Camara, who sought the release of his mother Leticia Lourdes A. Camara (Camara), Assistant Vice‑President of the Land Bank of the Philippines (LBP); respondent is Hon. Ernesto P. Pagayatan, presiding judge of the Regional Trial Court (RTC), San Jose, Occidental Mindoro, Branch 46. Also involved in the underlying litigation were Josefina S. Lubrica (respondent in the agrarian case) and Teresita V. Tengco (LBP officer).On 4 March 2005 the trial court in Civil Case No. R‑1390 (an agrarian just compensation proceeding arising from expropriation under P.D. No. 27) ordered LBP to "deposit the preliminary compensation ... in cash and bonds ... Php 71,634,027.30 with the Land Bank of the Philippines, Manila" within seven days. LBP appealed that order to the Court of Appeals (CA G.R. SP No. 93206), which dismissed the appeal on 17 August 2006; LBP moved for reconsideration. While that motion was pending, Lubrica filed in the trial court a motion to cite LBP officers for indirect contempt for noncompliance with the 4 March 2005 order.
In an Order dated 9 February 2007 the trial court found Camara and Tengco guilty of indirect contempt and issued warrants of arrest "until they comply with the order to deposit." Camara was arrested on 12 February 2007 and detained at the Provincial Jail, San Jose, Occidental Mindoro; Tengco evaded arrest. On 14 February 2007 LBP filed a Compliance, depositing the full P71,634,027.30 at its head office in Manila — P7,163,402.73 in cash and P64,470,624.57 in bond — the cash being under an account described "LBP ITF The Clerk of Court, RTC Branch 46 ... in the Matter of Agrarian Case No. 1390" and the bond made payable to the clerk of court. LBP moved for Camara's release and for quashal of the warrant.
At the 19 February 2007 hearing the trial court suggested that LBP change the account and payee names to read in favor of the "Office of Clerk of Court, RTC San Jose Occidental Mindoro, for the account of Josefina S. Lubrica ..."; LBP complied the same day. Yet in an Order of 21 February 2007 the trial court held LBP's Compliance insufficient because the deposit was not "in such form that the Respondent Josefina S. Lubrica may immediately withdraw the same without any difficulty" and directed LBP to place the payments in Lubrica's name as payee. The trial court kept the arrest warrant in force.
On 23 February 2007 LBP, Camara, and Tengco filed a petition for certiorari and mandamus in the Court of Appeals, docketed CA G.R. SP No. 98032, and sought a writ of preliminary mandatory injunction to secure Camara's release. Petitioner filed a petition for writ of habeas corpus in the Supreme Court on 27 February 2007. The Supreme Court issued the writ on 2 March 2007 directing Judge Pagayatan to bring Camara to the Court on 5 March 2007 fo...(Subscriber-Only)
Issues:
- Did the trial court act with grave abuse of discretion amounting to lack or excess of jurisdiction in refusing to release Camara despite LBP's deposit of the full preliminary compensation?
- Was Camara's detention unlawful such that the Supreme Court should grant habeas corpus relief and prohibit re‑imprison...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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