Facts:

The case involves the Commissioner of Immigration as the petitioner and Hon. Gaudencio Cloribel, Judge of the Court of First Instance of Manila, along with respondents Mercedes Tobiano Co., Jose Tobiano, and Justo Tobiano. The events leading to this case began when the Commissioner of Immigration filed a petition for certiorari with a preliminary injunction on February 8, 1965. This was against Judge Cloribel for allegedly exceeding his jurisdiction by granting bail to Jose and Justo Tobiano during their habeas corpus proceedings. The Commissioner argued that the authority to grant bail in deportation cases lies solely with the Bureau of Immigration, not the courts. On February 10, 1965, the Supreme Court accepted the petition and issued a writ of preliminary injunction, allowing the respondents ten days to respond.

In their response filed on February 18, 1965, the respondents sought dismissal of the petition, claiming it was premature since no motion for reconsideration h...

Facts:

1. Background of the Case:
   The Commissioner of Immigration filed a petition for certiorari with preliminary injunction on February 8, 1965, against Judge Gaudencio Cloribel of the Court of First Instance of Manila. The petition sought to challenge the judge's order releasing respondents Jose Tobiano and Justo Tobiano on bail during the pendency of their habeas corpus proceeding. The Commissioner argued that the power to grant bail in exclusion or deportation cases lies with the Bureau of Immigration, not the court.

2. Initial Proceedings:
   On February 10, 1965, the Supreme Court gave due course to the petition and issued a writ of preliminary injunction. Respondents filed an answer on February 18, 1965, seeking dismissal of the petition on the grounds that it was premature and that certiorari was not the proper remedy since an appeal was available.

3. Detention Conditions:
   Respondents Jose and Justo Tobiano had been detained for about six months at Engineering Island, Bureau of Immigration. They filed an urgent petition on March 30, 1965, highlighting the inhumane conditions of their detention, including overcrowding, poor sanitation, and substandard nutrition. They also cited a similar case where the Court of Appeals had granted bail.

4. Solicitor General's Position:
   The Solicitor General, representing the Commissioner of Immigration, initially opposed the grant of bail but later left the matter to the Supreme Court's discretion, acknowledging the delay in resolving the case and the complexity of the legal issues involved.

5. Subsequent Motions and Resolutions:
   Respondents filed multiple motions reiterating their plea for bail, citing the harsh conditions of detention and invoking principles of liberty and justice. On August 30, 1965, the Supreme Court amended its earlier injunction, allowing the respondents to be released on bail (P25,000 each) under conditions similar to those in a related case.

6. Final Resolution:
   The Supreme Court dismissed the petition for certiorari, rendering the issue of bail moot and academic. The Court noted that the legal question raised was significant but deferred its re-examination to a more appropriate case.

Issue:

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Ruling:

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Ratio:

1. Jurisdiction Over Bail in Deportation Cases:
   The Supreme Court reaffirmed its previous rulings (Bengzon v. Ocampo, Tiu Chun Hai v. Deportation Board, and Ong Hee Sang v. Commissioner of Immigration) that the power to grant bail in exclusion or deportation cases is vested in the Bureau of Immigration, not the courts. However, in this case, the Court exercised its discretion to grant bail due to the inhumane conditions of detention and the delay in resolving the case.

2. Humanitarian Considerations:
   The Court considered the harsh and insanitary conditions of detention at Engineering Island as a compelling factor in granting bail. It emphasized the primacy of liberty and the need to protect individuals from undue suffering while their cases are pending.

3. Mootness of the Issue:
   The Court ruled that the issue of bail had become moot and academic after it permitted the respondents' release on bail. It deferred the re-examination of the legal question to a future case where the parties could fully argue the matter in an adversarial proceeding.