G.R. No. 59118 - Dizon vs. Eduardo

Petitioners Juan Dizon and Soledad Ramos filed a petition for habeas corpus on behalf of their children, Eduardo Dizon and Isabel Ramos, respectively.
Eduardo Dizon (30 years old) was described as a community leader and self-employed businessman despite having only one arm, while Isabel Ramos (22 years old) was a former architecture student.
Both were arrested by military personnel without warrants or presidential orders on September 15, 1981, at Barangay Sto. Rosario, Sta. Ana, Pampanga, by elements under Col. Teddy Carian.
They were detained at the Philippine Constabulary (PC) stockade in San Fernando, Pampanga, under the regional jurisdiction of Brig. Gen. Vicente Eduardo and Col. Carian for interrogation without assistance of counsel.
The military claimed they were released after nine days on September 24, 1981, supported by release papers bearing their signatures. However, the petitioners alleged the signatures were falsified and the detainees have not been seen or heard from since their supposed release.
The petitioners challenged the validity of the alleged release and doubted the truthfulness of the military’s account, contending the military used the release as a scheme to prolong illegal detention and continued torture.

Case refers extensively to the martial law era under President Ferdinand Marcos (September 1972 – 1986) during which many opposition leaders, journalists, and activists, including former detainees like Senator Jose Wright Diokno and Benigno “Ninoy” Aquino Jr., were arrested, detained, tortured, or disappeared.
Senator Diokno and Ninoy Aquino had both been detained without formal charges during martial law, subjected to disappearances themselves, and had reportedly endured harsh conditions such as solitary confinement.
The Supreme Court and international human rights bodies have condemned arbitrary arrests and detentions, and the United Nations General Assembly issued resolutions condemning involuntary disappearances.
The petitioners relied on the United Nations General Assembly Resolution on Disappeared Persons (December 20, 1978) which calls on governments to search for disappeared persons, ensure accountability of law enforcement, and safeguard human rights.

Petitioners filed their habeas corpus petition on December 17, 1981. The Supreme Court issued a writ of habeas corpus on December 24, 1981.
Respondents filed a return on January 5, 1982, denying illegal detention and asserted the detainees were released on September 24, 1981, submitting affidavits of Major Reynaldo C. Cabauatan and 1st Lt. Roque S. Maranon supporting the alleged release.
Petitioners challenged the genuineness of the detainees’ signatures on the release documents by presenting specimen signatures from official government records (voter registration, statements, booking sheets) showing notable differences.
Respondents disputed the signature analysis, arguing the specimen signatures were xerox copies and not reliable for forensic comparison.
Respondents failed to follow standard release procedures including:

Not releasing detainees to their parents or other responsible persons despite visitation privileges being active
Not reporting the release to the Ministry of Defense within the required 72 hours; respondents did not notify Brig. Gen. Eduardo or Defense Minister Juan Ponce Enrile
Delay in providing copies of release certificates to parents (one month for Isabel Ramos, three months for Eduardo Dizon)
Lack of authority of Col. Carian to release detainees arrested in flagrante delicto with unlicensed firearms without presidential or authorized approval under General Order No. 67 (October 8, 1980)

Respondents claimed the detainees agreed to act as spies and were released accordingly, but the Court found this justification implausible given prior facts, absence of precautions to ensure compliance, and that the detainees failed to report after release.
The Court found grave doubts about respondents’ claim of release given the irregularities, forged or falsified release certificates, and suspicious circumstances surrounding the disappearance.
The Court acknowledged that it was not a trier of facts and could not conduct a full investigation into the serious charges or the whereabouts of the detainees.
The case was pending during the Marcos regime’s martial law and subsequent revolution in February 1986, culminating in the establishment of the Presidential Committee On Human Rights (PCHR) chaired by Diokno himself, and eventually the Constitutional creation of the Commission on Human Rights in 1987 to handle such cases.
The Court ultimately referred the case to the Commission on Human Rights for full investigation and appropriate action.

When the military claims that detainees have been released but petitioners dispute such release and the detainees have remained missing, who bears the burden of proof on the issue of detention or release?
Whether respondents proved by clear and convincing evidence that the detainees were actually released on September 24, 1981.
What remedies or relief can the Court grant petitioners if respondents are unable or refuse to produce the bodies of the desaparecidos despite failing to prove release?