Mesina v. Ramas
REITERATIONFacts
The Antecedents: This case concerns the alleged unlawful detention of Marcelo A. Mesina, a licensed foreign exchange dealer. Petitioner Monico B. Biglaen, acting on behalf of Mesina, asserted that Mesina was forcibly taken from his place of business by individuals posing as law enforcement officers and subsequently confined without any formal complaint, accusation, or judicial writ. Procedural History: The petition for a writ of habeas corpus was filed by Monico B. Biglaen on behalf of Marcelo A. Mesina. The Supreme Court issued the writ on October 4, 1983, directing the respondents to file a return and setting a hearing. However, prior to the filing of the return, a motion to withdraw the petition was filed, stating that Mesina had been released on October 10, 1983. The Petition: The petition sought the issuance of a writ of habeas corpus to secure the release of Marcelo A. Mesina, who was allegedly being unlawfully deprived of his liberty. The petitioner argued that Mesina's detention was illegal because no formal charge had been filed against him, no judicial warrant had been issued, and his business of foreign exchange was authorized by the Central Bank of the Philippines. The petition was ultimately withdrawn and dismissed as moot and academic following Mesina's release.
Issue(s)
Whether the detention of Marcelo A. Mesina is illegal. Whether the petition for habeas corpus has become moot and academic.
Ruling
The petition is dismissed for being moot and academic.
Ratio Decidendi
On the illegality of detention: The petition alleged that Marcelo A. Mesina was unlawfully detained without any formal charge or judicial writ. The petitioner asserted that Mesina was a licensed foreign exchange dealer and had committed no offense justifying his deprivation of liberty. The circumstances described in the petition indicated a potential violation of Mesina's right to liberty. On the mootness of the petition: The Court noted that prior to the scheduled hearing and before the respondents filed their return, a motion to withdraw the petition was filed. This motion explicitly stated that Marcelo A. Mesina had already been released from military custody on October 10, 1983. The respondents' return confirmed this release and attached a receipt executed by Mesina's wife. Consequently, the issue of unlawful detention, which was the subject of the habeas corpus petition, ceased to exist. The Court reiterated its established jurisprudence that when the person detained is released, the petition for habeas corpus becomes moot and academic, citing Herrera v. Enrile and analogous cases. Therefore, the Court found no further necessity to proceed with the hearing or to rule on the merits of the alleged illegal detention.
Main Doctrine
A petition for habeas corpus becomes moot and academic when the person detained is released.