CASE DIGEST: G.R. No. L-4 and G.R. No. L-19. Promulgated: September 4, 1945

 ANGEL CRUZ Y ENCARNACION, petitioner-appellant, vs. GUILLERMO CABRERA, Judge of Municipal Court of Manila, respondent-apellee.

Crime: Qualified Theft

Law: Criminal Law

Legal Queries raised: Jurisdiction, Bench Warrant, Habeas Corpus

Cited Law/Order: Com. Act No. 361

Famous statement from this jurisprudence:

The remedy of habeas corpus cannot be legally and properly invoked when the right of appeal exists because the main purpose of the writ of habeas corpus is to determine if petitioner is legally detained

FACTS:

Petitioner-appellant, accused, commits a crime of qualified theft of eight (8) cases of storage batteries.

RULING:

1. Yes, City of Manila has jurisdiction to try theft cases, as long as the amount involved does not exceed P200 per Administrative Code.

2. That respondent judge of the municipal court of the City of Manila has authority to issue such a bench warrant is clearly shown by the provisions of section 2469 of the Revised Administrative Code.

3. At issue in the habeas corpus case, has become a moot question by reason that petitioner-appellant is already guilty of the crime and he appeal. The remedy of habeas corpus cannot be legally and properly invoked when the right of appeal exists because the main purpose of the writ of habeas corpus is to determine if petitioner is legally detained. Habeas corpus cannot be properly invoked to correct alleged errors committed by the trial court, which had jurisdiction of the person and the subject-matter, unless such errors made the judgment absolutely void.

Lesson of this case: 

Jurisdiction and issuance of Bench Warrant be based in the law. Writ of Habeas Corpus be availed before judgment of the court as guilty and appealed the case to the higher court. The main purpose of the writ of habeas corpus is to determine if petitioner is legally detained.

Full text of the case: https://lawphil.net/judjuris/juri1945/sep1945/gr_l-4_1945.html

Cited Jurisprudence:

People vs. De Leon, 49 Phil., 437;

People vs. Kaw Liong, 57 Phil., 839, 841, 842;

People vs. Acha, 40 Off. Gaz., 2d Supp., No. 5, p. 252;

People vs. Del Mundo,

SC-G. R. No. 46531, Oct. 18, 1939;

People vs. San Juan, 40 Off. Gaz., 6th Supp., No. 10, p. 45

U. S. vs. Galanco, 11 Phil., 575

Cowper vs. Dade, 29 Phil., 222;

Abanilla vs. Villas, 56 Phil., 481;

Paguntalan vs. Director of Prisons, 57 Phil., 140, 144

Andres vs. Wolfe, 5 Phil., 60;

U. S. vs. Jayme, 24 Phil., 90.