FRANCO, MANUEL JOSEPH U.

CLAW | JD-1B TTh | 2:30-4:30PM

MEDINA VS. OROZCO

GR NO. L26723
December 22, 1966
FACTS:
On November 7, 1965 at 12:00PM, petitioner Arthur Medina was arrested and incarcerated in the
Caloocan City Jail. He was allegedly one of those responsible for the death of one Marcelo
Sangalang. At around 9:00AM of that same day, the case against Medina and two others was
referred to a fiscal, who forthwith conducted preliminary investigation in petitioner's presence.
Only on November 10, 1965 that an information was filed against them in the Caloocan of the
Court of First Instance of Rizal. The court promptly ordered them to be committed to jail.
ISSUE:
Whether or not Orozco committed arbitrary detention by delay in the delivery of the detained
person to proper judicial authorities.
HELD:
No, Orozco did not violate article 125, arbitrary detention by delay in the delivery of the detained
person to proper judicial authorities.
It was a fact that only after 75 hours that an information was filed at the Caloocan Branch of the
Court of First Instance of Rizal but this does not equate to arbitrary detention because to consider
that November 7 was a Sunday, November 8 was declared an official holiday and November
9 was an election day. It would not be an easy task for a fiscal to look for personnels of the court
and the judge likewise to properly file the complaint. These considerations were taken into by the
Supreme Court in holding that Orozco can't be liable for arbitrary detention under article 125.