So v. Tacla
REITERATIONFacts
The Antecedents: David E. So filed a petition for writs of habeas corpus and amparo on behalf of his daughter, Maria Elena So Guisande, who was accused of Qualified Theft, a non-bailable offense. So alleged that Guisande was in a life-threatening situation while confined at the National Center for Mental Health (NCMH), to which she was referred by the Regional Trial Court (RTC) of Mandaluyong City for an independent assessment of her mental health to determine her fitness to stand trial. Guisande had previously been committed by So for psychiatric treatment at Makati Medical Center, where she was diagnosed with Bipolar Mood Disorder. Procedural History: Following the RTC's order for Guisande's referral to the NCMH, she was placed under the temporary legal custody of Dr. Bernardo A. Vicente, Chief of NCMH, and confined at the NCMH. Guisande and her father subsequently filed a Motion for Relief from Solitary Confinement with the RTC and a petition for habeas corpus and amparo with the Supreme Court, alleging life-threatening circumstances and violations of her rights during confinement. The Supreme Court issued a joint writ of habeas corpus and amparo, referring the case to the Court of Appeals (CA) for hearing. The NCMH submitted an evaluation report deeming Guisande competent to stand trial. The CA, in its resolution, ordered the resumption of the trial, Guisande's transfer to St. Clare's Medical Center under NBI custodial control, and periodic medical reports, ultimately closing and terminating the habeas corpus and amparo petition. The Petition: The Office of the Solicitor General (OSG) filed a petition for review on certiorari under Rule 45 of the Rules of Court, assailing the CA's resolution. This petition was consolidated with the original petition for habeas corpus and amparo. Subsequently, the OSG filed a manifestation and motion to dismiss both consolidated petitions, arguing they were rendered moot and academic by the dismissal of the Qualified Theft case against Guisande. The OSG also presented resolutions from the Assistant City Prosecutor dismissing charges of falsification against Judge Tacla and Dr. Vicente, and the CA's dismissal of a contempt petition against them. The Supreme Court agreed with the OSG, denying the petitions for being moot and academic due to the supervening event of the dismissal of the underlying criminal case.
Issue(s)
Whether the petitions for writs of habeas corpus and amparo, and the petition for review on certiorari, have become moot and academic due to the dismissal of the underlying criminal case. Whether the confinement of Ma. Elena So Guisande at the National Center for Mental Health was illegal or unlawful, and whether the acts of Judge Esteban A. Tacla, Jr. and Dr. Bernardo A. Vicente in ascertaining Guisande's mental condition were unlawful.
Ruling
The petitions in G.R. Nos. 190108 and 190473 are DENIED for having been rendered moot and academic.
Ratio Decidendi
On the issue of mootness: The Court held that the petitions for habeas corpus and amparo, and the petition for review on certiorari, were rendered moot and academic by the dismissal of the criminal case for Qualified Theft against Ma. Elena So Guisande. The dismissal of the criminal case meant that Guisande was no longer under threat of confinement in a jail facility, nor could her person or treatment be subjected to the lawful processes of the RTC. Therefore, any declaration on the petitions would serve no practical use or value, as the supervening event of the criminal case's dismissal rendered the controversy non-justiciable. The Court cited David v. Macapagal-Arroyo in defining a moot and academic case as one that ceases to present a justiciable controversy by virtue of supervening events. On the legality of confinement and acts of respondents: The Court found that the question before the CA was limited to which hospital Guisande should be referred for treatment, and it was procedurally proper for the RTC to seek an opinion on her mental fitness to stand trial. The CA's order allowing transfer to St. Clare's Medical Center under specific conditions, while continuing the trial, indicated that Guisande remained in the custody of the law to answer the charge. The Court noted that nowhere in the CA proceedings was the confinement at NCMH declared illegal, nor were the acts of Judge Tacla and Dr. Vicente declared unlawful. The NCMH had assessed Guisande as fit for trial. The Court reiterated that the Rules on Habeas Corpus and Amparo require an illegal or unlawful act or omission as the basis for the issuance of the writs. Since the underlying criminal case was dismissed, the basis for the claims of illegal confinement and unlawful restraint was removed, rendering the petitions moot.
Main Doctrine
The petitions for writs of habeas corpus and amparo, as well as the petition for review on certiorari, were denied for having been rendered moot and academic by the dismissal of the underlying criminal case for Qualified Theft, as the subsequent events rendered the issues no longer justiciable and without practical use or value.