Title
Agcaoili, Jr. vs. Farinas
Case
G.R. No. 232395
Decision Date
Jul 3, 2018
"Ilocos 6" employees detained during a House inquiry on alleged misused excise taxes; Supreme Court dismissed habeas corpus petition as moot, emphasizing legislative limits and judicial independence.

Case Summary (G.R. No. 164007)

Petitioner and Co-petitioner Claims

• Ilocos 6 filed for Habeas Corpus before the Court of Appeals (CA) after being cited in contempt and detained for non-attendance at congressional hearings on House Resolution No. 882. They ask the Supreme Court to assume jurisdiction over that petition.
• Governor Marcos filed a petition for Prohibition under Rule 65 to enjoin the congressional inquiry as illegal and discriminatory, and for a writ of Amparo to protect all petitioners from alleged violations of liberty and security.

Respondents’ Position

• The House Committee defends its inquiry in aid of legislation under Section 21, Article VI of the 1987 Constitution and House rules. It argues prohibition lies not against legislative functions.
• Detabali and the House contend the Habeas Corpus petition became moot upon the petitioners’ release, and the Supreme Court cannot wrestle jurisdiction from the CA.

Key Dates

• March 14, 2017: Introduction of House Resolution No. 882 investigating Ilocos Norte’s use of tobacco excise shares for vehicle purchases.
• May 2, 2017 and May 16, 2017: Initial hearings; petitioners absent, subpoenas issued.
• May 29, 2017: Petitioners attend, allege intimidation, are cited in contempt, and detained.
• May 30, 2017: Petitioners file Habeas Corpus in CA.
• June 9, 2017: CA grants provisional release on bond; Detabali fails to accept service.
• July 3, 2017: CA Justices defer actions to Supreme Court En Banc.
• July 13, 2017: Ilocos 6 and Marcos file Omnibus Petition in the Supreme Court.
• July 25, 2017: House Committee lifts contempt; petitioners released.
• August 31, 2017: CA dismisses Habeas Corpus as moot.

Applicable Law

• 1987 Constitution, Articles III and VI (due process, inquiries in aid of legislation); Article VIII (judicial power, Supreme Court’s jurisdiction and administrative supervision).
• Rules of Court, Rules 4, 58, 102 (writs of prohibition, preliminary injunction, habeas corpus).
• Rule on the Writ of Amparo.
• Batas Pambansa Blg. 129 and R.A. 7902 (CA’s habeas corpus jurisdiction).
• House Rules Governing Inquiries.

Procedural History

Ilocos 6 were subpoenaed as resource persons in a congressional inquiry into provincial fund disbursements. Citing insufficient notice and questioning methods, they missed early hearings, then attended on May 29, 2017 and were cited in contempt for allegedly evasive testimony. They were detained, prompting a Habeas Corpus petition in the CA. While the CA granted release upon bond, enforcement failed. Meanwhile, the CA Justices faced a House reciprocal contempt threat, leading them to refer pending motions to the Supreme Court. Petitioners then filed an Omnibus Petition in the Supreme Court seeking to transfer the CA’s habeas corpus case, prohibit the legislative inquiry, and obtain Amparo relief. The House lifted the contempt order and released petitioners before the Supreme Court’s decision.

Issues for Resolution

  1. Has the Habeas Corpus petition become moot by subsequent release?
  2. Can the Supreme Court assume jurisdiction over a habeas corpus petition already pending in the CA?
  3. May a writ of prohibition enjoin the pending legislative inquiry?
  4. Does the petition state a cause for a writ of Amparo?

Supreme Court Ruling

  1. Mootness of Habeas Corpus Petition
    – Subsequent release of petitioners rendered the habeas corpus petition moot and academic. Without illegal restraint, courts lose jurisdiction to act.
    – Exceptionally, moot questions may be decided for public interest, but no voluntary withdrawal or judicial order voiding jurisdiction remained; the CA itself terminated the petition as moot.

  2. Assumption of Jurisdiction
    – The Supreme Court, CA, and Regional Trial Courts share concurrent original jurisdiction over habeas corpus under the Constitution and statute.
    – Jurisdiction once acquired by the CA cannot be wrested away by the Supreme Court’s administrative supervisory powers.
    – Administrative supervision (Art. VIII, Sec. 6) and Rule 4, Sec. 3(c) of A.M. No. 10-4-20-SC pertain to venue transfers to prevent injustice—not to reassign jurisdiction from one coequal court to an

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