Case Digest (G.R. No. 154598) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Richard Brian Thornton (petitioner), an American citizen, for and in behalf of his minor daughter Sequeira Jennifer Delle Francisco Thornton, versus Adelfa Francisco Thornton (respondent), the spouses had contracted marriage on August 28, 1998 at the Catholic Evangelical Church in Manila. One year later, the respondent gave birth to their daughter. After three years as a housewife, respondent resumed her former work as a guest relations officer in a nightclub and frequently left home with friends, entrusting the child to household help. On December 7, 2001, without notifying petitioner, respondent departed their Makati residence with the child, claiming she was taking her to Basilan Province. Petitioner filed a petition for writ of habeas corpus in the Family Court of Makati City, which was dismissed, and an initial search in Basilan proved futile. He later discovered cellular records placing respondent and the child in various provinces. Petitioner then filed a second petiti Case Digest (G.R. No. 154598) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioner: Richard Brian Thornton, an American citizen, filed the petition for writ of habeas corpus on behalf of his minor daughter, Sequeira Jennifer Delle Francisco Thornton.
- Respondent: Adelfa Francisco Thornton, Filipino citizen and mother of the minor child.
- Marriage and Family Circumstances
- Marriage solemnized on August 28, 1998 at the Catholic Evangelical Church, Manila.
- Birth of Sequeira Jennifer in 1999; respondent later grew restless and resumed nightlife activities, leaving the child with household help.
- Disappearance of Mother and Child
- On December 7, 2001, respondent departed the family home with Sequeira without notifying petitioner, allegedly bound for Purok Marikit, Sta. Clara, Lamitan, Basilan.
- Petitioner’s search efforts:
- Habeas corpus petition in Makati Family Court dismissed for alleged lack of territorial jurisdiction.
- Personal search in Basilan proved fruitless; barangay certification confirmed respondent’s non-residence.
- Additional investigations based on respondent’s phone records indicated movements across Cavite, Nueva Ecija, Metro Manila, and other provinces.
- Petition in the Court of Appeals
- Petitioner filed a second petition for writ of habeas corpus in the Court of Appeals (CA G.R. SP No. 70501).
- Court of Appeals’ July 5, 2002 resolution dismissed the petition on grounds of:
- Lack of subject-matter jurisdiction—exclusive original jurisdiction vested in Family Courts under RA 8369.
- Insufficiency in substance.
Issues:
- Jurisdictional Scope
- Whether the Court of Appeals retains jurisdiction to issue writs of habeas corpus in custody cases involving minors despite RA 8369’s grant of “exclusive original jurisdiction” to Family Courts.
- Legislative Repeal and Statutory Harmony
- Whether RA 8369 impliedly repealed BP 129 (1981) and RA 7902 (1995), which confer nationwide habeas corpus jurisdiction upon the Court of Appeals.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)