Case Digest (G.R. No. L-200)
Facts:
Anastacio Laurel was arrested in Camarines Sur in May 1945 by the United States Army for alleged active collaboration with the Japanese, interned, and in September 1945 was delivered to the Commonwealth Government and placed under the custody of Eriberto Misa, Director of Prisons. He petitioned for a writ of habeas corpus chiefly contending that Commonwealth Act No. 682, especially section 19, is unconstitutional; the Solicitor General defended the Act and stated an information for treason was ready for filing.
Issues:
- Does section 19 of Commonwealth Act No. 682 deny the equal protection of the laws by singling out political prisoners?
- Does section 19 effect an unlawful delegation of legislative power to the Special Prosecutors' Office?
- Is section 19 retroactive or an unconstitutional ex post facto law as applied to petitioner?
- Is petitioner entitled to immediate release by writ of habeas corpus?
Ruling:
The Court denied the petition for the writ of habeas corpus and upheld the constitutionality of the challenged portions of section 19 of Commonwealth Act No. 682, finding no repugnancy to the Constitution on the grounds urged. A separate opinion by Justice Perfecto dissented and would have ordered petitioner released for violation of constitutional rights.
Ratio:
The Court found the classification reasonable and justified by emergency circumstances, General MacArthur's proclamation and Executive Order No. 65, and the practical necessity of giving prosecutors time to investigate some six thousand detainees rather than indiscriminately indicting all. The six-month suspension of Article 125 of the Revised Penal Code was held a limited, temporal measure compatible with legislative power and mitigated by bail provisions; permitting prosecutors to file informations within that period did not constitute an unconstitutional delegation. The provision was not retroactive as it applied to detention after the Act's passage, and procedural or remedial statutes may be applied prospectively.
Doctrine:
- Emergency and special circumstances may justify reasonable legislative classification affecting procedural rights of a defined class of detainees.
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