Tujan-Militante v. Cada-Deapera
REITERATIONFacts
1. The Antecedents: Respondent Raquel M. Cada-Deapera initiated a special civil action for a writ of habeas corpus before the Regional Trial Court (RTC) of Caloocan City, seeking the immediate production and return of her biological daughter, minor Criselda M. Cada, from the custody of petitioner Ma. Hazelina Tujan-Militante. Petitioner had allegedly taken the child and was keeping her from respondent. 2. Procedural History: The respondent filed the habeas corpus petition on March 24, 2011, with RTC-Caloocan, which issued the writ the following day. Despite attempts, the sheriff could not personally serve the petitioner, but left copies of the petition and writ at her Caloocan residence on March 29, 2011. Petitioner failed to appear. Subsequently, petitioner filed a guardianship case in RTC-Quezon City, which was dismissed due to litis pendentia with the pending habeas corpus case. An alias writ of habeas corpus was issued by RTC-Caloocan on August 8, 2011, and served upon petitioner during a preliminary investigation in Quezon City. Petitioner moved to quash the writ and dismiss the petition, arguing lack of jurisdiction due to improper service. RTC-Caloocan denied this motion. Petitioner then filed a petition for certiorari with the Court of Appeals (CA), which also dismissed her petition, affirming the RTC's jurisdiction and the validity of the service. Petitioner sought reconsideration, which the CA denied. 3. The Petition: Petitioner filed a petition for review on certiorari under Rule 45 of the Rules of Court, seeking to reverse the CA's decision and resolution. The core of her argument is that the RTC-Caloocan lacked jurisdiction to hear and decide the habeas corpus case concerning the custody of a minor residing in Quezon City, and that jurisdiction was not validly acquired over her person or the minor due to improper service of the writ. She contends that the habeas corpus petition should have been filed in the family court with jurisdiction over her place of residence or the minor's residence, and that personal service of the writ was essential for acquiring jurisdiction.
Issue(s)
Whether the Regional Trial Court of Caloocan City has jurisdiction over the habeas corpus petition and whether the writ issued by the RTC-Caloocan is enforceable in Quezon City where the petitioner was served a copy thereof. Whether the RTC-Caloocan validly acquired jurisdiction over the person of the petitioner and the minor.
Ruling
The petition is denied. The Court of Appeals Decision dated May 17, 2013 and its Resolution dated December 27, 2013 are affirmed. The RTC-Caloocan correctly took cognizance of the habeas corpus petition and validly acquired jurisdiction over the petitioner.
Ratio Decidendi
On the jurisdiction of the RTC-Caloocan and the enforceability of the writ in Quezon City: The Court affirmed that the RTC-Caloocan has jurisdiction over the habeas corpus proceeding. The petition was filed under Section 20 of A.M. No. 03-04-04-SC and Rule 102 of the Rules of Court. Section 20 states that a petition for a writ of habeas corpus involving custody of minors shall be filed with the Family Court, and the writ shall be enforceable within its judicial region. However, it also allows filing with regular courts in the absence of a Family Court judge or where no Family Courts exist. Crucially, the writ issued by a Family Court or a regular court is enforceable within the judicial region to which they belong. Since Caloocan City and Quezon City both belong to the National Capital Judicial Region, a writ issued by the RTC-Caloocan is enforceable in Quezon City. Therefore, the location of the petitioner's or the minor's residence within the National Capital Judicial Region is immaterial for the purpose of filing the petition, as long as the writ is sought to be enforced within that region. The Court clarified that Section 3 of A.M. No. 03-04-04-SC, which specifies filing based on residence, applies only to petitions for custody of minors, not to habeas corpus petitions. As established, both Caloocan City and Quezon City are within the National Capital Judicial Region. Section 20 of A.M. No. 03-04-04-SC explicitly states that the writ shall be enforceable within the judicial region to which the Family Court or regular court belongs. Therefore, the RTC-Caloocan, as a court within the National Capital Judicial Region, could validly issue a writ enforceable within the same region, including Quezon City, where the petitioner was served. On the acquisition of jurisdiction over the petitioner and the minor: The Court held that the RTC-Caloocan validly acquired jurisdiction over the person of the petitioner. The Court reiterated the ruling in Saulo v. Brig. Gen. Cruz, stating that a writ of habeas corpus plays a role comparable to a summons in ordinary civil actions. By the service of the writ, the Court acquires jurisdiction over the person of the respondent. In this case, the Sheriff personally served the alias writ upon the petitioner in Quezon City. This personal service, even if made outside the territorial jurisdiction of the RTC-Caloocan but within the same judicial region, was sufficient to confer jurisdiction over her person. The Court emphasized that personal service does not necessarily mean service exclusively at a given address; it can be made wherever the person may be found. The Court also clarified that service of summons, as required in ordinary civil actions, is not necessary in a habeas corpus petition.
Main Doctrine
A Regional Trial Court within a judicial region has jurisdiction to issue a writ of habeas corpus involving custody of minors, and such writ is enforceable within the same judicial region, irrespective of the specific city or municipality of residence of the petitioner or the minor within that region. Service of the writ itself, not formal summons, is what confers jurisdiction over the person of the respondent in a habeas corpus proceeding.