Santos v. Philippine Training School for Girls
REITERATIONFacts
The Antecedents: Virginia Santos, a minor accused of violating a municipal ordinance, was committed to the Philippine Training School for Girls by the municipal court of Manila. Procedural History: The court below, in a habeas corpus proceeding, ordered the release of Virginia Santos, holding that the act for which she was tried had prescribed, thus there was no cause of action against her. The Petition: The respondent, the Superintendent of the Philippine Training School for Girls, appealed the order of release.
Issue(s)
Whether the defense of prescription of an offense is a valid ground for a writ of habeas corpus. Whether the municipal court had jurisdiction to commit Virginia Santos to the Philippine Training School for Girls.
Ruling
The Supreme Court reversed the order of the court below, denied the writ of habeas corpus, and ordered the immediate release of Virginia Santos from the Philippine Training School for Girls. The bond filed by her was ordered cancelled.
Ratio Decidendi
On the issue of prescription as a ground for habeas corpus: The Court held that the defense of prescription must be alleged during the proceedings in the prosecution of the offense. It is not a ground for the issuance of a writ of habeas corpus. The Court cited North American jurisprudence which states that the statute of limitations must be set up at the trial and is not available on an application for a writ of habeas corpus. Questions that may arise in the orderly course of a criminal prosecution are to be determined by the court to whose jurisdiction the defendant has been subjected, and a good defense to a charge will not entitle a defendant to discharge on habeas corpus. The Court distinguished this from lack of jurisdiction, which annuls all proceedings. Prescription does not deprive a court of jurisdiction; rather, it means the State loses the right to prosecute. The proper action upon a plea of prescription is to exercise jurisdiction and decide the case on its merits, holding the action to have prescribed and absolving the defendant. On the issue of the municipal court's jurisdiction: The Court found no merit in the contention that the municipal court lacked jurisdiction. Act No. 3203 confers jurisdiction upon any court before whom a minor is accused. Section 3 of said Act provides for the commitment of a minor accused in any court of an offense not punishable by life imprisonment or death. Therefore, the municipal court had the jurisdiction to commit Virginia Santos.
Main Doctrine
The defense of prescription of an offense is not a ground for the issuance of a writ of habeas corpus, as it must be raised during the proceedings in the prosecution of the offense. Lack of jurisdiction is a ground for habeas corpus, but prescription does not deprive a court of jurisdiction.