Mangila v Pangilinan

Nature of the case: Petition for Writ of Habeas Corpus

Doctrine: The object of a writ of habeas corpus is to inquire into the legality of the detention, and, if
found illegal, require the release of the detainee. Equally well-settled is that the writ will not issue
where the person in whose behalf the writ is sought is out on bail or is in the custody of an officer under
process issued by a court of judge with jurisdiction.

Petitioners

Respondents

Facts:

- Petitioner Anita Mangila and 4 others were charged with criminal complaints of syndicated
estafa filed in Puerto Princesa MTCC. This was because of their recruiting and promising
employment overseas to people. They collected visa processing fees, membership fees, and
online application fees without the authorization from the POEA. After examination by JUDGE
PANGILINAN, a warrant for the arrest of Mangila without bail was issued. Thereafter, the entire
record of the case was sent to the City Prosecutor of Puerto Princesa for further proceedings
and appropriate action.
- Mangila was arrested and detained at the NBI HQ. She claimed that respondent judge did not
have authority to conduct the preliminary investigation, and the same was not completed which
entails that the issuance of the warrant was without sufficient justification. She then filed a
petition for habeas corpus to obtain her release from detention. She justified this petition
stating that she could no longer file a motion to quash or to recall the warrant because the
records of the case has already been transmitted to Puerto Princesa.
- CA denied the petition for habeas corpus. The CA explained that the writ of habeas corpus will
not be granted when the petitioner has not exhausted all remedies available to him/her. Her MR
was likewise denied. Hence, this appeal.

Issue:

- Is Habeas Copus the proper remedy for Mangila? NOPE

Fallo

- WHEREFORE, the court AFFIRMS the resolutions promulgated by the CA and ORDERS the
petitioner to pay for the suit.

Held

- The writ of Habeas Corpus is devised as a speedy and effective remedy against unlawful
restraint or detention.
- The court cited the case of Caballes v CA to discuss the nature of the writ.
o The writ seeks the enforcement of civil rights. It is not to inquire into criminal act of
which the complaint is made but into the right of liberty or relief from illegal restraint.
 o The writ is not in the nature of a writ of error, nor as a substitute for the trial court’s
function. It cannot be used to investigate questions of error that might be raised relating
to procedure.
o The inquiry in a habeas corpus proceeding is addressed to the question of whether the
proceedings and the assailed order are null and void.
- The object of a writ of habeas corpus is to inquire into the legality of the detention, and, if found
illegal, require the release of the detainee. Equally well-settled is that the writ will not issue
where the person in whose behalf the writ is sought is out on bail or is in the custody of an
officer under process issued by a court of judge with jurisdiction.

Notes

- For the issue that Judge Pangilinan had no power to conduct the preliminary investigation. The
judge is empowered to conduct such investigation involving all crimes cognizable by the proper
court in their respective territorial jurisdiction. (Sec 2, Rule 112 Revised Rules of Criminal
Procedure)
377561285