Title
IN RE: Ilagan vs. Enrile
Case
G.R. No. 70748
Decision Date
Oct 21, 1985
Attorneys arrested and detained in Davao City question the legality of their arrest and detention, but the court dismisses their petition for habeas corpus as moot and academic due to the subsequent filing of criminal charges against them.
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Case Digest (G.R. No. 70748)

Facts:

  • Petitioners Laurente C. Ilagan, Antonio B. Arellano, and Marcos D. Risonar, Jr., all attorneys, were arrested in Davao City on May 10, 1985, by the Philippine Constabulary-Integrated National Police (PC-INP).
  • They were detained at Camp Catitipan based on Mission Orders allegedly issued by the Ministry of National Defense.
  • The Integrated Bar of the Philippines (IBP), the Free Legal Assistance Group (FLAG), and the Movement of Attorneys for Brotherhood, Integrity, and Nationalism (MABINI) filed a petition for habeas corpus on their behalf.
  • The petitioners argued that the arrests were illegal and violated the Constitution, suggesting a military campaign to harass lawyers involved in national security cases.
  • The Supreme Court issued a writ of habeas corpus on May 16, 1985, and set a hearing for May 23, 1985.
  • During the hearing, the detained attorneys narrated their arrest circumstances, while the respondents presented evidence of subversive activities in Davao.
  • Due to a lack of evidence linking the attorneys to these activities, the Court ordered their temporary release on recognizance.
  • Respondents filed an urgent motion for reconsideration, claiming the suspension of the writ of habeas corpus ousted the Court's jurisdiction.
  • An Information for Rebellion was filed against the detained attorneys on May 27, 1985, rendering the petition moot and academic according to the respondents.

Issue:

  • (Unlock)

Ruling:

  1. The Supreme Court dismissed the petition for habeas corpus, declaring it moot and academic due to the filing of an Information for Rebellion against the detained attorneys.
  2. The Court held that the remedy of habeas corpus no longer lies as the detained attorneys' incarceration was now by virtue of a judicial order in relation to criminal cases filed against them.
  3. The Court stated tha...(Unlock)

Ratio:

  • The Supreme Court reasoned that the function of habeas corpus is to inquire into the legality of one's detention.
  • Since the detained attorneys were now held under a judicial order following the filing of criminal charges, the writ of habeas corpus had served its purpose.
  • The Court cited Rule 102, Section 4, which states that if a person is in custody under a process issued by a court with jurisdiction, the writ shall ...continue reading

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