G.R. No. 157007 - Salic vs. Commission on Elections

Regina Paz Lopez, then a minor, was confined at the Dare Foundation, Inc., a rehabilitation center headed by Fr. Bob Garon, on an accusation of violating the Dangerous Drugs Act (Republic Act No. 6425).
The confinement was linked to her affiliation with petitioner Ananda Marga Pracaraka Samgha in the Philippines, Inc., a socio-religious organization, and her decision to leave the country to further her religious studies in India against her mother’s wishes.
It was contended that her confinement constituted a violation of a basic constitutional right, particularly the right to due process, as it was effected without affording her an opportunity to be heard.

The petition for habeas corpus was issued, and the case was duly returned for hearing.
On July 10, 1974, the Court issued a resolution directing both parties to indicate within five days whether they agreed to dismiss the case and withdraw the petition, while temporarily granting custody of Regina to her mother, Conchita Lopez.
Subsequent pleadings revealed that Regina had disappeared; her whereabouts were later determined, and the matter was rescheduled for another hearing aimed at settling the differences between the mother and daughter and providing Regina an opportunity to demonstrate that she was not drug dependent.

On October 2, 1974, a new resolution directed respondent Judge Onofre Villaluz to proceed expeditiously with the hearing of Voluntary Submission Case No. 557 (filed by Conchita Lopez) pursuant to Section 30 of RA 6425 to determine Regina’s status regarding drug dependency.
On October 7, 1974, Judge Villaluz filed a manifestation noting several key points:

He had received the Supreme Court’s directive to conduct the hearing on the voluntary submission case.
Regina had been voluntarily submitted to the court for treatment and rehabilitation on July 4, 1974, and was committed to the Dare Foundation on the same date.
The Court had ordered expert psychiatrists to conduct a thorough physical examination to ascertain whether Regina was a drug dependent and/or suffered from a personality disorder, for which she was temporarily released to her parents’ custody.
Regina had escaped from the Dare Foundation on September 23, 1974, and her whereabouts remained unknown, rendering it impossible to serve the issued subpoenas and set a hearing at that time.

In the interim, Regina attained the age of majority, which fundamentally altered the legal basis of the proceedings that centered on her status as a minor.

Whether ordering the confinement of Regina Paz Lopez without affording her the opportunity to be heard violated her constitutional right to due process.
Whether the procedures followed, including the absence of a prior hearing before confinement, constituted a breach of procedural due process.

Whether the proceedings based on statutory provisions applicable to minors could continue after Regina attained the age of majority.
Whether the case could still yield a useful judicial determination given the disappearance of Regina and the subsequent impossibility of serving subpoenas.

Whether the directive to proceed under Section 30 of RA 6425 was appropriate in view of Regina’s subsequent disappearance and attainment of majority.
How the interplay between administrative orders and judicial mandates affected the legitimacy of the ongoing proceedings.