May a person convicted by final judgment and/or out on bail is entitled to a writ of habeas corpus?
May the Court, in habeas corpus proceedings, review the record in a criminal case after judgment of conviction has been rendered?
Facts: The trial court found Garcia guilty of three (3) counts of falsification of public documents. The CA confirmed the conviction. Out on bail, Garcia filed a petition for habeas corpus with the Supreme Court, questioning the validity of the judgment rendered. Garcia contends that where proceedings were attended by violations of the constitutional rights of the accused, the judgment of conviction is void thereby warranting relief by the extraordinary legal remedy of habeas corpus. The OSG, on the other hand, states that the writ of habeas corpus is a remedy available to a person who is illegally imprisoned or restrained by his liberty. Consequently, a person discharged or out on bail, like petitioner, is not entitled to the writ.
Held: The high prerogative writ of habeas corpus was devised and exists as a speedy and effectual remedy to relieve persons from unlawful restraint. Its object is to inquire into the legality of ones detention, and if found illegal, to order the release of the detainee. However, it is equally well-settled 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 or judge or by virtue of a judgment or order of a court of record, and that the court or judge had jurisdiction to issue the process, render the judgment, or make the order. In the case at bar, therefore, petitioner can no longer seek relief via a petition for habeas corpus having been convicted by final judgment of the crime of falsification of public document and use thereof. Said judgment is already final and executory.
Even if we disregard the fact that petitioner is out on bail, the writ prayed for should not be granted. Indeed, we have held that once a deprivation of a constitutional right is shown to exist, the court that rendered the judgment is deemed ousted of jurisdiction and habeas corpus is the appropriate remedy to assail the legality of his detention. Petitioner, however, has failed to persuade this Court that the proceedings before the trial court were attended by violations of her right to due process, or for that matter, other constitutional rights.
It is apparent from the arguments advanced by petitioner that the purpose of this petition is to cause this Court to once again re-examine and pass judgment upon the trial courts appreciation of the evidence presented. But the writ of habeas corpus is not a remedy for the correction of such errors. Court cannot, in habeas corpus proceedings, review the record in a criminal case after judgment of conviction has been rendered, and the defendants have entered on the execution of the sentence imposed, to ascertain whether the facts found by the trial court were in accordance with the evidence disclosed by the record, or to pass upon the correctness of conclusions of law by the trial court based on the facts thus found. Under the statute, a commitment in due form based on a final judgment convicting and sentencing a defendant in a criminal case is conclusive evidence of the legality of his detention under such commitment, unless it appears that the court which pronounced the judgment was without jurisdiction or exceeded its jurisdiction in imposing the penalty. Mere errors of fact or law, which did not have the effect of depriving the trial court of its jurisdiction over the cause and the person of the defendant, if corrected at all, must be corrected on appeal in the form and manner prescribed by law. [In Re: Azucena L. Garcia, 339 SCRA 292, GR 141443, August 30, 2000]
