G.R. No. L-54558 - Olaguer vs. Military Commission No. 34

December 24, 1979: Petitioners (all civilians) arrested by military authorities; initially detained at Camp Crame, then transferred to Camp Bagong Diwa (except Olaguer).
June 1980: Petitioner Mac Aceron surrenders and detained at Camp Bagong Diwa.

May 30, 1980: Petitioners charged with subversion under P.D. 885; case designated MC-34-1 upon Judge Advocate General’s recommendation and Defense Minister’s approval.
June 13, 1980: Chief of Staff creates Military Commission No. 34 to try the case.
July 30, 1980: Amended charge sheet filed alleging seven offenses, including unlawful possession of explosives, multiple conspiracies to assassinate, arson, attempted murder, and rebellion.

August 19, 1980: Petitioners file Petition for prohibition and habeas corpus to enjoin MC-34 and secure release, arguing lack of jurisdiction and due-process violations.
September 23, 1980–August 31, 1984: Respondents file Answer and Rejoinder; petitioners file Reply; petitioner Olaguer withdraws from the petition; Misa-Jimenez and others granted provisional liberty at various dates.
January 17, 1981: Proclamation 2045 lifts martial law, dissolves military tribunals upon final determination of pending cases.

December 4, 1984: MC-34 convicts petitioners and sentences them to death by electrocution, despite petitioners’ pending Supreme Court petitions.
February 14, 1985: Petitioners file second Petition for habeas corpus, certiorari, prohibition, mandamus, and preliminary injunction; Supreme Court issues TRO on September 12, 1985.
February 1986: Cases submitted for decision; most petitioners released before or after February 1986, rendering habeas corpus petitions moot.

Consideration of prior rulings (Aquino Jr. v. MC No. 2 and related cases) on military jurisdiction over civilians.
Recognition that civil courts had been open and functioning throughout martial law and after its lifting.
Re-examination of military tribunal jurisdiction in light of Proclamation 2045 and emerging constitutional safeguards.

Whether military commissions may lawfully try civilians for offenses alleged during martial law while civil courts are open and functioning.

Whether proceedings before Military Commission No. 34 violated petitioners’ constitutional right to due process (trial by impartial judicial tribunal, opportunity to present evidence).

Whether the habeas corpus petitions became moot and academic upon petitioners’ provisional release from military detention.

Whether the doctrine in Aquino Jr. v. MC No. 2 and subsequent affirming cases should be abandoned or modified in light of constitutional developments and separation-of-powers principles.