Case Digest (G.R. No. 11157)
Facts:
Policarpio Ramirez v. Francisco de Orozco, G.R. No. 11157, March 25, 1916, the Supreme Court, Johnson, J., writing for the Court.Petitioner Policarpio Ramirez filed an original petition for the writ of habeas corpus alleging unlawful restraint by respondent Francisco de Orozco, warden of the provincial prison of Pangasinan. Ramirez claimed his detention was effectively imprisonment for debt in contravention of Section 5 of the Act of Congress of July 1, 1902, which prohibited imprisonment for debt in the Philippine Islands.
The petition included the sworn complaint, arrest warrant, the justice of the peace's memorandum of arraignment, and the justice's sentence. The complaint charged Ramirez with violating Section 1 of Act No. 2098 (an Act governing the hiring of personal services), alleging that on or about November 6 (or 16), 1914, Ramirez induced Alejandro Santos to pay P16 into the municipal treasury by promising to render personal services in exchange for cedulas, but then failed to perform, thereby defrauding Santos of P16. A warrant of arrest issued February 12, 1915.
On June 2, 1915, Ramirez was brought before the Justice of the Peace of San Jacinto, arraigned without counsel, advised of his rights, and pleaded guilty verbally and by thumb mark in the presence of witnesses; the justice certified the plea. The justice later rendered sentence finding Ramirez guilty under Section 1 of Act No. 2098 and sentenced him to four months' imprisonment, ordered restitution of P16 to the offended party, and imposed costs.
Upon filing, the Court issued an order to show cause. The Attorney-General, answering for the respondent on September 6, 1915, admitted some facts, denied that Ramirez was imprisoned for debt because Ramirez had been sentenced for an infraction of Section 1 of Act No. 2098, and asserted that the statute punished a special kind of estafa rather than imposing imprisonment for nonpayment of debt or involuntary servitude; consequently, the statute was not void or unconstitutional.
After examining the constitutional question presented, the Court concluded that Act No. 2098 was constitutiona...(Subscriber-Only)
Issues:
- Was petitioner Ramirez being unlawfully imprisoned for debt in violation of Section 5 of the Act of Congress of July 1, 1902?
- Is Section 1 of Act No. 2098 (the law under which Ramirez was convicted) constitutional and within the power of the Philippine L...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
- (Subscriber-Only)