Case Digest (G.R. No. L-3676)
Facts:
In In the Matter of the Petition for Habeas Corpus (279 Phil. 266, En Banc, G.R. Nos. 81567, 84581–82, 84583–84, 83162, 85727, 86332, Oct. 3, 1991), several groups of petitioners—Roberto Umil, Rolando Dural and Renato Villanueva (with their relatives); Amelia Roque and Wilfredo Buenaobra; Atty. Domingo Anonuevo and Ramon Casiple; Vicky Ocaya and Danny Rivera; Deogracias Espiritu; and Alfredo Nazareno—sought relief from alleged unlawful custody by military and police officers under respondents including then Gen. Fidel Ramos, Gen. Renato de Villa, Brig. Gen. Ramon Montano, Brig. Gen. Alexander Aguirre, and local police commanders. In each case, the petitioners had been arrested without warrants between May 1988 and December 1988—Dural for membership in the outlawed CPP/NPA and subversion after being identified in St. Agnes Hospital as a wounded “sparrow”; Roque, Buenaobra, Anonuevo, Casiple and Ocaya for possession of unlicensed firearms, ammunition and subversive documents founCase Digest (G.R. No. L-3676)
Facts:
- Consolidated Habeas Corpus Petitions
- Multiple petitions (G.R. Nos. 81567; 84581-82; 84583-84; 83162; 85727; 86332) filed by Roberto Umil, Rolando Dural, Renato Villanueva, Manolita Umil, Nicanor Dural, Felicitas Sese, Amelia Roque, Wilfredo Buenaobra, Domingo Anonuevo, Ramon Casiple, Vicky Ocaya, Deogracias Espiritu and Alfredo Nazareno.
- Respondents included President Ramos, military and police officers, and commanding officers of detention centers.
- The Court’s 9 July 1990 decision dismissed all petitions except reducing bail for Espiritu (G.R. No. 85727) from P60,000 to P10,000.
- Circumstances of Arrests Without Warrant
- Rolando Dural (G.R. 81567) arrested at St. Agnes Hospital (1 Feb 1988) as a suspected NPA “sparrow” tied to the Jan. 31 shooting of two CAPCOM policemen; identity based on “confidential information.”
- Roque, Buenaobra, Anonuevo, Casiple and Ocaya arrested (May–Aug 1988) in “safehouses” pursuant to search warrants; found with unlicensed firearms, ammunition and subversive documents; caught in flagrante delicto.
- Espiritu (G.R. 85727) arrested (23 Nov 1988) for allegedly inciting to sedition at a drivers’ rally and National Press Club conference.
- Nazareno (G.R. 86332) arrested (28 Dec 1988) for investigation of the 14 Dec murder of Romulo Bunye II based on co-suspect’s pointing him out; information filed 3 Jan 1989.
- Motions for Reconsideration
- Petitioners challenged validity of warrantless arrests, reliance on Rule 113, Sec. 5, and continued application of Garcia v. Enrile and Ilagan v. Enrile.
- Alleged violations of constitutional rights, misappreciation of facts, improper use of extrajudicial admissions, and mootness of certain cases.
Issues:
- Whether arrests without warrant complied with Rule 113, Section 5 of the Rules of Court.
- Whether membership in CPP/NPA or subversion constitutes a “continuing offense” justifying warrantless arrest.
- Whether extrajudicial admissions of membership and possession of firearms and documents were admissible.
- Whether the doctrines in Garcia v. Enrile and Ilagan v. Enrile remain valid.
- Whether any petitions became moot or academic.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)