Case Digest (G.R. No. L-1159)
Facts:
In Cecilio M. Lino v. Valeriano E. Fugoso, G.R. No. 1159, decided January 30, 1947 under the 1935 Constitution, petitioner Cecilio M. Lino filed a petition for a writ of habeas corpus on behalf of twelve Manila municipal workers allegedly arrested without warrant between November 5 and November 8, 1946, and detained in the City Jail of Manila by respondents Mayor Valeriano E. Fugoso, Chief of Police Lamberto Javalera, and the jail officer John Doe. Respondents’ return admitted the warrantless arrests but explained that, upon investigation by the City Fiscal on November 11, 1946, ten detainees were released for insufficiency of evidence on inciting to sedition, while Pascual Montaniel and Pacifico Deoduco remained in custody under newly filed informations in the municipal court for unjust vexation (Art. 287, RPC) and disobedience to police orders (Art. 151, RPC), respectively. No warrants of arrest or commitment had been issued. By minute resolution, the Supreme Court initially dCase Digest (G.R. No. L-1159)
Facts:
- Parties and petition
- Petitioners: Twelve members of the City Employees’ and Workers’ Union (CLO) alleging unlawful detention.
- Respondents: Valeriano E. Fugoso (Mayor), Lamberto Javalera (Chief of Police), John Doe (Officer in charge of the municipal jail of Manila).
- Arrests and detentions
- Between November 5 and 8, 1946, police arrested:
- Four men for distributing handbills during a labor strike.
- Three for possessing strike notices.
- One for wearing a strike band (”Damayan kami! Huag mag-iskirol!”).
- One for greeting a non-striker.
- One for entering a guarded motor-pool.
- No warrants issued at time of arrest; detainees held beyond six hours without delivery to judicial authorities.
- Referral and release
- On November 11, the petition for habeas corpus was filed; City Fiscal received case papers late that afternoon.
- City Fiscal dismissed sedition charges against ten detainees and recommended their release.
- Montaniel and Deoduco remained in custody; municipal court complaints filed Nov 11–12 for unjust vexation and disobedience.
Issues:
- Whether detention without warrant beyond six hours violates Article 125 of the Revised Penal Code (as amended).
- Whether filing of informations by the City Fiscal cures detention illegally continued after six hours.
- Whether City Fiscal constitutes a “proper judicial authority” under Article 125.
- Whether light offenses under Articles 151 and 287, punishable by arresto menor or fine, justify continued arrest absent a judicial order (Rule 108, sec. 10).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)