Saturday, March 27, 2021

CASE DIGEST: G.R. Nos. L-1 and L-2. Promulgated: December 4, 1945

 THE PEOPLE OF THE PHILIPPINES vs. JUAN NAVARRO and ANACLETO ATIENZA


Crime: Illegal Detention

Law: Criminal Law

Cited Jurisprudence: None

Cited Law/Order: None


FACTS:

Defendants, being a public officials detain Esteban P. Beloncio in the Provincial Jail of Mindoro for more than fifteen days but less than six months.

RULING:

The defense thoroughly answered these points.

“if the informations must be quashed on the ground ‘that the facts charged do not constitute an offense’ xxxxx ‘in the informations’ must be the one examined and analyzed to determined the sufficiency of the allegations.”

He also maintains that it was error for the court to make findings of facts and decide the criminal cases on the merits, before issue had been joined, and before any evidence had been properly presented.

The Beloncios were thus deprive of their liberty by order of the military authorities, a few days after the liberation of Mindoro.


Lesson for this case: 

Illegal detention is prohibited. When an accused is detained by the authorities, he is already in detain. He cannot be detained from one law enforcement agency to the other.


Full text of the case: https://lawphil.net/judjuris/juri1945/dec1945/gr_l-1-2_1945.html

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