Case Digest (G.R. No. 153945)
Facts:
In Lily Raquiza et al. v. Lt. Col. L. J. Bradford et al. (75 Phil. 50, September 13, 1945), petitioners Lily Raquiza, Haydee Tee Han Kee, and Emma Link Infante filed a petition for a writ of habeas corpus on August 30, 1945, alleging illegal detention at the Correctional Institution for Women in Mandaluyong. Each was arrested by U.S. Army Counter Intelligence Corps (“CIC”) personnel under General MacArthur’s December 29, 1944 Proclamation. Raquiza was taken on March 13, 1945, charged with “espionage activity for Japanese” (Schedule A); Tee Han Kee on February 25, 1945, for “active collaboration with the enemy” (Schedule A-2); and Infante on April 10, 1945, for “active collaboration with the Japanese” (Schedule A-1). Their commitment orders authorized custody “for the duration of the war” until released by competent military authority. Respondents Lt. Col. Bradford and Capt. Caroline De Eason filed returns attaching these orders and MacArthur’s proclamation, asserting lawful miliCase Digest (G.R. No. 153945)
Facts:
- Petition and parties
- Petitioners: Lily Raquiza, Haydee Tee Han Kee, Emma Link Infante – allege illegal restraint of liberty.
- Respondents: Lt. Col. L. J. Bradford, Capt. Inez L. Twidle (Counter Intelligence Corps, U.S. Army) and other U.S. military officers.
- Arrests and commitment orders
- General Douglas MacArthur’s proclamation (Dec. 29, 1944): Authorized detention of Filipinos who aided the enemy “for the duration of the war,” with post-war release to Philippine Government.
- Lily Raquiza (Mar. 13, 1945): Arrested by 306th CIC, Sixth Army; detained under Security Commitment Order No. 385 (Schedule A); charged with “Espionage activity for Japanese.”
- Haydee Tee Han Kee (Feb. 25, 1945): Arrested by 306th CIC; detained under Security Commitment Order No. 286 (Schedule A-2); charged with “Active collaboration with the enemy.”
- Emma Link Infante (Apr. 10, 1945): Arrested by 493rd CIC, USAFFE; detained under Commitment Order (Schedule A-1); charged with “Active collaboration with the Japanese.”
- Habeas corpus proceedings
- Petition filed August 30, 1945: Sought release via writ of habeas corpus.
- Orders to show cause issued August 31 and September 7, 1945; respondents returned with the above commitment orders and invoked MacArthur’s proclamation and military necessity.
Issues:
- Whether Philippine civil courts have jurisdiction to entertain a writ of habeas corpus against U.S. military officers detaining petitioners under MacArthur’s proclamation.
- Whether the state of war has legally terminated so that the foundation for detention no longer exists.
- Whether petitioners’ detention without formal charge or trial violates due process and warrants their release.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)