Case Summary (G.R. No. 268876)
Nature of the Petition
Angeli E. Akabane filed a Petition for Habeas Corpus on behalf of her partner, Dr. Benigno A. Agbayani, Jr., who was convicted of reckless imprudence resulting in serious physical injuries. The petition argues that Dr. Agbayani was unlawfully deprived of his liberty due to violations of his due process rights and questions the validity of a judgment that has become final and executory.
Background Facts
Dr. Agbayani was found guilty by the MeTC for using an unsterilized medical instrument during a surgical operation, resulting in serious harm to a patient. The case went through multiple stages, including an appeal to the Regional Trial Court (RTC), which ultimately dismissed Dr. Agbayani's appeal for failing to submit a required memorandum. The dismissal was later upheld by the Court of Appeals (CA) and the Supreme Court.
Legal Proceedings Chronology
- The petitioner was charged with criminal neglect leading to serious injury and was sentenced to two years.
- The RTC dismissed his appeal for failing to meet filing deadlines despite being granted extensions.
- The CA confirmed the RTC's dismissal, noting that non-compliance with procedural requirements justified the dismissal of the appeal.
- The Supreme Court affirmed this in resolutions dated June 23, 2021, and March 16, 2022, culminating in the issuance of a warrant for Dr. Agbayani’s arrest.
Arguments Presented in the Petition
Angeli argues that the RTC's dismissal of Dr. Agbayani's appeal violated his due process rights and thus renders the judgment void and subject to challenge through habeas corpus. She further asserts that, regardless of the finality of the conviction, Dr. Agbayani had already served more time than his sentence.
Court's Analysis
The Court determined that a Petition for Habeas Corpus is inappropriate as Dr. Agbayani was lawfully detained following due judicial process. The issuance of the warrant and subsequent imprisonment were based on valid court judgments, thereby making his detention lawful.
Conclusion by the Court
The Court ultimately dismissed the petition for habeas corpus, concluding:
- The remedy sought was not appropriate as he was in custody based on a process issued by a court of record.
- His arrest was lawful, stemming from a conviction that cannot be challenged through the habeas corpus mechanism.
- The Court reaffirmed that the issues raised concerning procedural irregularities in prior judgments were not grounds for habeas
Case Syllabus (G.R. No. 268876)
Facts of the Case
- Dr. Benigno A. Agbayani, Jr. was convicted by the Metropolitan Trial Court (MeTC), Branch 13 of Manila for reckless imprudence resulting in serious physical injuries.
- The conviction stemmed from a criminal case involving the use of an allegedly unsterilized medical instrument during an operation on Saul Q. HofileAa, Jr.'s left knee, which caused infection and serious injury.
- The MeTC sentenced Dr. Agbayani to two years of prision correccional minimum.
- The Court of Appeals (CA) dismissed Dr. Agbayani’s petition for review due to procedural infirmities including failure to file a proper appeal memorandum and failure to attach necessary pleadings and records.
- The Supreme Court affirmed the CA's dismissal with modification of the penalty.
- Dr. Agbayani's subsequent petitions for reconsideration and motions to elevate the case were denied.
- Following the finality of the Court’s resolution, a warrant of arrest was issued and served, resulting in Dr. Agbayani’s incarceration at Manila City Jail.
- The petition for habeas corpus was filed by Angeli E. Akabane, his common-law spouse, contesting the legality of the detention.
Charging and Trial Details
- Dr. Agbayani was charged in 2008 under an Amended Information for reckless imprudence leading to serious physical injuries, specifically for using an unsterilized arthroscope.
- The prosecution presented several witnesses, including the complainant Saul, medical professionals, and witnesses who testified about the infection and evidence related to the alleged negligence.
- Documentary exhibits included affidavits, medical reports, sterilization records, admission slips, and laboratory reports proving infection.
- Dr. Agbayani pleaded not guilty and claimed lack of responsibility for sterilization and handling of the medical instrument.
Trial and Judgment
- The MeTC, Branch 13 ruled Dr. Agbayani guilty on July 29, 2013, after concluding the prosecution sufficiently proved negligence causing infection.
- The MeTC found Dr. Agbayani failed to observe the required degree of care and diligence.
- The judgement imposed a penalty of two years of prision correccional minimum.
Appeal Proceedings
- Dr. Agbayani filed an appeal but failed to timely file his memorandum of appeal despite extensions granted.
- After multiple failed motions for extension, the RTC Manila dismissed the appeal on December 23, 2013 for failure to file the memorandum.
- The Court of Appeals denied his Petition for Review for lack of merit, underscoring the procedural failures and absence of required documentary attachments.
- The Supreme Court affir