Yambert v. McMicking
REITERATIONFacts
The Antecedents: Arthur F. Yambert, a public official, was tried with one Manion by Judge Araullo in the Court of First Instance of Manila for falsification of a public document. Yambert was convicted of a violation of article 568 of the Penal Code, relating to reckless negligence. Procedural History: On January 27, 1908, Yambert applied to Judge Crossfield of the same court for a writ of habeas corpus. Judge Crossfield, believing that the facts stated in Judge Araullo's judgment did not justify the sentence, held the judgment void and released Yambert. The sheriff of Manila appealed this order. The Petition: The sheriff appealed the order of Judge Crossfield releasing Yambert, arguing that Judge Crossfield had no authority to review the errors of Judge Araullo.
Issue(s)
Whether Judge Crossfield, through a writ of habeas corpus, had the authority to revise errors of fact or law committed by Judge Araullo in the criminal prosecution of Yambert. Whether Judge Crossfield had the authority to interfere with a prisoner being tried by another judge via a writ of habeas corpus.
Ruling
The order of Judge Crossfield is reversed. Yambert is ordered to be remanded to the custody of the sheriff of the city of Manila.
Ratio Decidendi
On the issue of revising errors of fact or law: The Supreme Court held that, according to repeated decisions and section 528 of the Code of Civil Procedure, Judge Crossfield, by means of the special proceeding in habeas corpus, had no authority to revise any errors, either of fact or of law, which he supposed had been committed by Judge Araullo in the criminal prosecution against Yambert and Manion. The writ of habeas corpus is not an appellate remedy for the correction of errors of judgment. On the issue of interfering with a prisoner being tried by another judge: The Court further stated that the judge who made the order appealed from disregarded the law in force in the Islands, according to which no judge should, by writ of habeas corpus, interfere with a prisoner who is being tried by another judge. In this case, the writ of habeas corpus was issued and decided before the time to appeal from the judgment of Judge Araullo had expired, thus constituting an improper interference.
Main Doctrine
A writ of habeas corpus cannot be used to review errors of fact or law committed by a judge in a criminal prosecution, nor can it be used to interfere with a prisoner being tried by another judge.