Case Digest (G.R. No. 14639) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Zacarias Villavicencio et al. v. Justo Lukban et al., G.R. No. L-14639, decided March 25, 1919, petitioners—relatives and friends of approximately 170 women confined in the segregated district for prostitutes in Manila—filed an application for habeas corpus before the Supreme Court. Between October 16 and 25, 1918, Mayor Justo Lukban, aided by Chief of Police Anton Hohmann, ordered the closure of the district on Gardenia Street, Sampaloc, and had the women locked in their homes. On the night of October 25, police forcibly loaded the inmates onto the steamers Corregidor and Negros bound for Davao, Mindanao, without their consent or opportunity to collect belongings. Upon arrival on October 29, 1918, the women were delivered to Provincial Governor Francisco Sales and hacendero Feliciano Ynigo, neither of whom had prior notice of the women’s status. Some deportees married, others worked or disappeared, while a number returned to Manila at their own expense. The original writ, ma Case Digest (G.R. No. 14639) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Context
- Petitioners were relatives and friends of approximately 170 women zoned as “women of ill repute” in Manila’s segregated district.
- Respondents included Justo Lukban (Mayor of Manila), Anton Hohmann (Chief of Police), Francisco Sales (Governor of Davao), Feliciano Ynigo (haciendero), and other municipal officers.
- Deportation of the Women
- Between October 16 and 25, 1918, city police confined the women to their district homes, then at night on October 25 forcibly loaded them onto steamers Corregidor and Negros bound for Davao, Mindanao.
- The women were neither informed nor consenting to deportation; they believed they were taken for investigation. Upon arrival (October 29), they were received by Bureau of Labor and Constabulary detachments and turned over to Sales and Ynigo as “laborers.”
- Habeas Corpus Proceedings
- Late October 1918: Petitioners filed for habeas corpus in the Supreme Court on behalf of all deported women, alleging illegal restraint by Mayor Lukban, Chief Hohmann, and unnamed parties.
- November 4, 1918: Supreme Court issued writ returnable December 2, naming Lukban, Hohmann, Sales, and Ynigo.
- December 2, 1918 Hearing: None of the women were produced; seven had returned at personal expense; testimony taken via commissioner.
- December 10, 1918: Court’s second order directed production by January 13, 1919, or written waivers/impossibility statements.
- January 13, 1919 Hearing: Respondents produced eight women; reported 81 renounced return, 59 had come back by other means, 26 remained unlocated. Counsel filed motions for contempt and striking pleadings.
Issues:
- Jurisdiction and Venue
- Whether the Supreme Court of the Philippines could issue and enforce a nationwide writ of habeas corpus.
- Whether the petition should have been filed or made returnable in the Court of First Instance of Davao.
- Standing and Remedy
- Whether relatives and friends had locus standi to file habeas corpus for the women.
- Whether habeas corpus was the proper and exclusive remedy for unlawful internal deportation.
- Continuity of Restraint
- Whether the women’s removal to Davao without consent constituted “restraint of liberty” sufficient for habeas corpus.
- Whether respondents, having transferred custody, retained power to comply with court orders.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)