Case Digest (G.R. No. 247490)
Facts:
Norberto Feria y Pacquing has been detained since May 21, 1981 after his conviction for Robbery with Homicide in Criminal Case No. 60677 by the Regional Trial Court (RTC) of Manila, Branch 2, for the jeepney robbery and killing of Peace Corps volunteer Margaret Viviene Carmona. In June 1993, petitioner sought transfer from Manila City Jail to the Bureau of Corrections in Muntinlupa, but the Jail Warden required the Commitment Order, Decision, and Information, which were missing. Inquiry revealed that the records were destroyed in the Manila City Hall fire of November 3, 1986. On October 3, 1994, petitioner filed a petition for writ of habeas corpus before the Supreme Court, claiming that absence of a valid judgment violated his constitutional due process rights. The Court issued the writ, raffled the case to RTC-Manila, Branch 9, which on November 15, 1994 dismissed the petition, holding that loss of records does not invalidate a judgment and that the proper remedy is reconstituCase Digest (G.R. No. 247490)
Facts:
- Background of Detention
- Norberto Feria y Pacquing was arrested and detained on May 21, 1981, following his conviction by the Regional Trial Court (RTC) of Manila, Branch 2, for Robbery with Homicide in Criminal Case No. 60677 involving the killing of a US Peace Corps volunteer.
- He was initially held at the Manila City Jail, later transferred to the Youth Rehabilitation Center in Muntinlupa, and subsequently to the Bureau of Corrections upon CA direction.
- Loss of Case Records
- On June 9, 1993, petitioner sought transfer from the Manila City Jail to the Bureau of Corrections; the Warden required submission of mittimus, judgment, and information.
- Counsel discovered that the entire records—commitment order, decision, information—were missing, apparently destroyed in the Manila City Hall fire of November 3, 1986.
- Habeas Corpus Proceedings
- October 3, 1994: Petitioner filed a petition for writ of habeas corpus in the Supreme Court, alleging illegal detention without a valid judgment copy and violation of due process.
- October 10, 1994: SC Second Division issued the writ, raffled the case to RTC-Manila Branch 9, and set a hearing for October 13, 1994.
- November 15, 1994: RTC Branch 9 dismissed the petition, ruling that loss of records does not void the judgment and that reconstitution is the proper remedy.
- April 28, 1995: Court of Appeals affirmed the RTC decision, allowing transfer without documents but without prejudice to record reconstitution.
- December 1, 1995: CA denied petitioner’s motion for reconsideration.
- Petition for Review on Certiorari
- Petitioner invoked errors of law before the Supreme Court, challenging the legality of his continued confinement and the authority of the CA resolution as a basis for detention.
- Petitioner argued that Sections 1 and 2 of Rule 120, requiring a written judgment, were not satisfied and that subsequent cases (e.g., Ordoñez) shifted reconstitution burden away from prisoners.
- The Office of the Solicitor General maintained that a lawful judgment existed, petitioner’s admissions and supporting documents proved conviction, and the proper remedy was reconstitution, not release.
Issues:
- Legality of Continued Incarceration
- Whether, under the peculiar circumstances of lost records, petitioner’s continued detention is justified by a valid conviction.
- Whether the CA resolution denying habeas corpus served as a “judgment” sufficient to support detention.
- Responsibility for Reconstitution
- Whether reconstitution of lost or destroyed records should be initiated by government organs in custody of the records.
- Whether the burden to reconstitute falls on the prisoner whose liberty is restrained.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)