Case Summary (G.R. No. 245617)
Criminal Complaints and Preliminary Investigation
On June 16, 2003 private complainants accused Mangila and four others of syndicating estafa and violating the Migrant Workers Act by recruiting overseas workers without POEA authority and collecting fees fraudulently. The following day, Judge Pangilinan conducted a preliminary investigation, examined one complainant under oath, found probable cause, and issued no-bail arrest warrants.
Arrest and Habeas Corpus Petition
After the MTCC records and warrants were transmitted to the City Prosecutor, Mangila was arrested on June 18, 2003 by NBI agents and detained in Manila. She filed a petition for habeas corpus in the Court of Appeals, contending that the investigating judge lacked authority, did not complete the inquiry before issuing the warrants, and that no prior finding of probable cause justified her arrest.
Court of Appeals Resolution
On October 14, 2003 the CA denied the petition for lack of merit, noting that habeas corpus is improper when other remedies (motion to quash or reinvestigation by the prosecutor) are available to challenge an allegedly invalid warrant. It held that Rule 112, Sec. 5, RCrP, provides for prosecutorial review of the investigating judge’s resolution, including the power to order release if no probable cause exists. A motion for reconsideration was likewise denied on November 19, 2003.
Issue Before the Supreme Court
Whether the CA erred in ruling that habeas corpus was not the proper remedy to secure Mangila’s release from a lawful, court-issued detention.
Nature and Scope of Habeas Corpus
Under Rule 102, RCoP, habeas corpus is a summary civil remedy limited to inquiring into the legality of deprivation of liberty, not to review procedural or substantive errors in pending criminal proceedings. The writ does not supplant motions to quash, trial, or appellate remedies and will not issue where detention is by process of a court of competent jurisdiction.
Authority of the Investigating Judge
Pursuant to Rule 112, Sec. 2(b), MTCC judges are empowered to conduct preliminary investigations over crimes within their territorial jurisdiction. Under Sec. 6(b), such a judge may issue an arrest warrant after examining the complainant and witnesses under oath and finding probable cause, even before completing the full investigation. Judge Pangilinan’s issuance of the warrant against Mangila thus fell squarely within his lawful authority.
Legality of Detention and Available Remedies
Because Mangila’s arrest and detention were pu
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Facts
- On June 16, 2003, seven criminal complaints were filed in the Municipal Trial Court in Cities of Puerto Princesa (MTCC), docketed as Criminal Cases Nos. 16916–16922, charging Anita Mangila and four others with syndicated estafa (Art. 315, RPC, in relation to PD 1689) and violation of Section 7(b), RA 8042, arising from recruitment of overseas workers to Toronto without POEA authority and collection of fees.
- On June 17, 2003, Judge Heriberto M. Pangilinan of the MTCC conducted a preliminary investigation, examined complainant Miguel Aaron Palayon under oath, found probable cause, and issued an arrest warrant without bail.
- On June 18, 2003, the MTCC records and the warrant were transmitted to the City Prosecutor of Puerto Princesa for review; Mangila was arrested and detained at the NBI headquarters on Taft Avenue, Manila.
- Mangila contended that Judge Pangilinan lacked authority to conduct a preliminary investigation, that the investigation was incomplete, and that the warrant was issued without probable cause or justification.
Procedural History
- Mangila filed a petition for writ of habeas corpus in the Court of Appeals (CA), alleging no other adequate remedy and seeking her immediate release.
- On October 14, 2003, the CA denied the petition, ruling that habeas corpus was not proper when other remedies—such as a motion to quash or a motion for reinvestigation before the municipal judge or a motion to secure release from detention before the provincial