De la Plata v. Escarcha
REITERATIONFacts
1. The Antecedents: Leonisa de la Plata filed a petition for habeas corpus on behalf of her son, Rodolfo, alleging his unlawful detention by respondent police officers of Manila Police Department Precinct No. 5. Rodolfo was apprehended on June 21, 1977, and subsequently charged with vagrancy. Additionally, Rodolfo was investigated for his alleged participation in a robbery in band that occurred in August 1976, signing a confession in the presence of his mother and brother. 2. Procedural History: Following the apprehension of Rodolfo de la Plata on June 21, 1977, he was charged with vagrancy in the city court of Manila on June 22, 1977. He pleaded guilty and was sentenced to ten days of arresto menor on June 29, 1977. Concurrently, Rodolfo was investigated for robbery in band, signing a sworn statement admitting his involvement. Subsequently, on June 29, 1977, he was committed to the custody of the Philippine Constabulary Metropolitan Command at Camp Crame by military authorities, citing Presidential Decree No. 9 in relation to General Order Nos. 2-A and 6. 3. The Petition: Leonisa de la Plata initiated this case by filing a petition for habeas corpus with the Supreme Court on June 22, 1977, seeking the release of her son, Rodolfo, from alleged unlawful detention. The Supreme Court issued the writ and required a return. The respondents, in their return, detailed Rodolfo's lawful detention for vagrancy and subsequent commitment to military custody for investigation into a robbery charge. At the hearing, the military authorities asserted justification for Rodolfo's detention. The petition argues that Rodolfo is lawfully detained, rendering the habeas corpus petition moot.
Issue(s)
Whether the petition for habeas corpus is in order given the detention of Rodolfo de la Plata by military authorities. Whether the detention of Rodolfo de la Plata is lawful.
Ruling
The petition for habeas corpus is dismissed. Rodolfo de la Plata is lawfully detained by the military authorities.
Ratio Decidendi
On whether the petition for habeas corpus is in order: The Court held that the petition for habeas corpus is not in order because Rodolfo de la Plata is lawfully detained by the military authorities. This conclusion is based on the fact that he was committed to the custody of the Philippine Constabulary Metropolitan Command at Camp Crame pursuant to Presidential Decree No. 9, in relation to General Order Nos. 2-A and 6. The Court cited the case of Romero vs. Ponce Enrile to support the principle that a writ of habeas corpus cannot be issued when the person detained is lawfully held by military authorities. The existence of a valid commitment order from military authorities, based on the cited decrees, negates the claim of illegal detention for the purpose of habeas corpus. The Court emphasized that the justification for detention by military authorities was manifested by Lieutenant Colonel Julian Alzaga of the Judge Advocate Staff Office. On whether the detention of Rodolfo de la Plata is lawful: The detention was deemed lawful because Rodolfo de la Plata was under lawful custody by virtue of a final judgment for vagrancy, having pleaded guilty and been sentenced by the city court. Furthermore, while under this lawful custody, he was taken to Camp Crame for investigation concerning his possible participation in a robbery in band with the use of a firearm. This subsequent detention by military authorities was justified under Presidential Decree No. 9 and General Orders Nos. 2-A and 6, the validity of which Rodolfo had not impugned. Therefore, his continued detention by the military was considered legal, precluding the issuance of a writ of habeas corpus.
Main Doctrine
A petition for habeas corpus will not prosper if the person detained is lawfully held by military authorities under Presidential Decree No. 9, even if the detention is for an offense cognizable by civil courts.