Case Digest (G.R. No. L-31435)
Facts:
Amalia B. Celeste v. People of the Philippines, Court of Appeals, and Judge Ruperto Kapunan, Jr., G.R. No. L-31435. January 30, 1970, the Supreme Court En Banc, Fernando, J., writing for the Court.Petitioner Amalia B. Celeste, then confined in the City Jail of Manila, sought restoration of her liberty by way of habeas corpus and, originally, by certiorari, injunction and mandamus. She attacked as null a decision of the Court of Appeals dated March 2, 1966, which had affirmed her conviction for estafa; what remained to be done was the formal reading of sentence by respondent Judge Ruperto Kapunan, Jr. Petitioner relied on an earlier Court of Appeals decision (April 11, 1960) in which, on an apparently similar transaction (sale of jewelry on commission), her liability had been treated as merely civil; she argued the later criminal conviction was inconsistent with that earlier disposition. The two cases involved different complainants (Victoria Vda. de Tengco in the 1960 case; Eden Patdo in the 1966 case) and apparently arose from several offended parties.
Petitioner alleged she had not known of the 1966 decision because her former counsel failed to inform her; the decision became final and executory while she was at liberty on bond. She was arrested and detained on December 13, 1969 pending reading of sentence and filed the original petition on January 5, 1970. On January 8, 1970 she converted the special proceeding into a petition for habeas corpus, asserting the illegality of her detention. The Court ordered the warden to produce petitioner and make a return; the Acting City Warden stated the offense charged was estafa (Crim. Case No. 41974). The Court of Appeals' March 2, 1966 conviction (and affirmance on appeal) was therefore the basis for the present detention.
The Supreme Court considered the petition but found no explicit allegation of denial of constitutional right and concluded that the habeas corpus remedy was not available to collaterally attack a valid, final and executory judgment of a court, absent a showing that the judgment proceeded from a tribunal whose jurisdiction was tainted by a deprivation of constitutional rights. Two members of the Court (the ponente and Justice Teehankee) stated they would not be averse to further inquiry if petitioner could plausibly show arbitrariness or a due process deprivation, but the Court—by majority—denied the petition f...(Subscriber-Only)
Issues:
- Is a petition for habeas corpus available to challenge detention that follows a final and executory judgment of the Court of Appeals?
- Were petitioner’s allegations sufficient to show a deprivation of constitutional rights or lack of jurisdiction in the Court of Appeals that would warrant relief by habeas corpus or an...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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