G.R. No. 230628 - Small Business Corp. vs. Commission on Audit

Petitioners are the mother and wife, respectively, of Michael Martinez, a resident of 4570 Cattleya Road, Sun Valley Subdivision, ParaAaque City.
Michael was allegedly abducted on November 19, 2001, around 7:30 in the morning while walking along Magnolia Street en route to his mother’s house at 3891 Marigold Street within the same subdivision.
The abduction was executed by seven unidentified persons.

Petitioners reported the incident to local authorities including the Barangay, the ParaAaque Police, and the Anti-Kidnapping Task Force stationed at Camp Crame.
The case attracted law enforcement attention and was also linked to a high-profile murder investigation—namely, the killing of Dorothy Jones (a.k.a. Nida Blanca).

In the evening of November 19, 2001, the Criminal Investigation and Detection Group (CIDG) of the Philippine National Police (PNP) presented Phillip Medel, Jr. before the media.

Medel testified that he had seen Michael Martinez while detained at the CIDG in Camp Crame, and later repeated similar assertions in a televised interview on November 26, 2001 and while speaking with Michael’s brother on November 27, 2001.
He even described the clothes Michael was allegedly wearing, which were noted to be the same as those worn at the time of the abduction.

Despite these assertions, there were inconsistencies in Medel’s testimony, which later played a major part in the evaluation of his credibility.

Following the reported abduction, petitioners made representations to the CIDG requesting the production or release of Michael Martinez.
Their representations were not granted, prompting them to file a petition for habeas corpus with the Regional Trial Court, Branch 78, Quezon City.

The Regional Trial Court (RTC) set the petition for hearing on December 3, 2001 and ordered respondents to show cause why the writ of habeas corpus should not issue.
During the December 3, 2001 hearing, respondents vehemently denied any custody or detention of Michael, stating that he was never confined by them.
Notwithstanding petitioner’s presentation of Phillip Medel Jr.’s testimony (including assertions of physical violence and evidence of detention), respondents maintained that Michael was not in their custody.
On December 10, 2001, the court directed respondents to produce Michael Martinez on the following day, December 11, 2001.
Later that day, respondents filed a notice of appeal, contesting the RTC’s decision, which ultimately led to the Court of Appeals reversing the trial court and dismissing the petition for habeas corpus.

The Court of Appeals (CA) scrutinized the evidence, noting that Phillip Medel, Jr.’s testimony was fraught with contradictions.
The CA also relied upon the testimony of Senior Superintendent Leonardo Espina, Sr., who stated that he was at home during the crucial hours between midnight of November 19 and early morning of November 20, 2001.
The respondents consistently maintained that Michael Martinez was never in their custody, invoking the presumption of regularity due to the routine performance of official duties within the CIDG.

Whether the Court of Appeals erred in reversing the trial court’s decision and dismissing the petition for habeas corpus.

The petitioner failed to make a categorical statement of the issues and did not specify the relief sought.
The central issue resolved by the higher court was whether there was legally sufficient evidence to establish that Michael Martinez was being unlawfully detained by the respondents.

Whether the evidence, particularly the conflicted testimony of Phillip Medel, Jr., was adequate to counter the respondents’ categorical denial of having custody of Michael Martinez.

The appropriate remedial action when the primary allegation relates to a person’s disappearance rather than clear evidence of illegal detention.