Primary Holding

The term "judicial authority" in Article 125 of the Revised Penal Code (RPC) refers exclusively to judges or courts, not to a city fiscal. Detaining an individual beyond the prescribed period, without delivering them to a proper judicial authority, is unconstitutional and illegal.

Background

Petitioners Melencio Sayo and Joaquin Mostero were arrested on April 2, 1948, for alleged robbery, based on a complaint by Bernardino Malinao. They were detained without a warrant and brought to the Office of the City Fiscal of Manila. When no proper court process was issued for their continued detention after six hours, they filed a petition for habeas corpus.

Facts

• 1. Sayo and Mostero were arrested without a warrant based on allegations of robbery.
• 2. They were delivered to the City Fiscal within the six-hour period mandated by Article 125 of the RPC.
• 3. The fiscal did not file a formal complaint with a court or secure a judicial order for their commitment or release.
• 4. Petitioners remained in custody beyond the legally permissible period, leading to their petition for habeas corpus.

Arguments of the Petitioners

• 1. Their detention violated Article 125 of the RPC and Section 1(3), Article III of the 1935 Constitution, which safeguards against unlawful seizures and detentions.
• 2. Delivering them to the City Fiscal does not fulfill the legal requirement of presenting them to a "judicial authority."
• 3. The continued delay in filing charges amounted to illegal detention.

Arguments of the Respondents

• 1. The arresting officer claimed compliance with Article 125 by delivering the petitioners to the City Fiscal within six hours.
• 2. The respondents sought to justify the continued detention as necessary for the fiscal’s investigation to determine probable cause.
• 3. They argued there was no bad faith in the detention, and that this procedure was aligned with established practices.

Issues

• 1. Does presenting an arrested person to a city fiscal comply with the requirement under Article 125 of the RPC to deliver the individual to a "judicial authority"?
• 2. Was the continued detention of the petitioners beyond six hours without a judicial order lawful?

Ruling

• 1. The Supreme Court held that Article 125 requires delivery of a detainee to a "judicial authority," which refers only to courts and judges authorized to issue detention or release orders.
• 2. Delivering petitioners to the City Fiscal of Manila does not satisfy this legal requirement.
• 3. The continued detention of petitioners beyond the six-hour period violated their constitutional right to liberty.
• 4. The Court ordered their release unless they were being detained under a proper court order.

Doctrines

• 1. Separation of Powers - Executive (fiscal) cannot exercise judicial functions
• 2. Due Process - Requires judicial warrant for extended detention
• 3. Constitutional Right against unreasonable seizure
• 4. Judicial Authority Doctrine - Limited to courts and judges

Key Excerpts

• 1. "The judicial authority mentioned in Article 125 of the Revised Penal Code cannot be construed to include the fiscal of the City of Manila or any other city."
• 2. "The right of the people to be secure in their persons... against unreasonable seizure shall not be violated."

Precedents Cited

• 1. Hashim v. Boncan, 40 OG 13th Supplement 13: Clarifies the scope of judicial authority.
• 2. Lino v. Fugoso, G.R. No. L-1159 (1947): Reiterated that a fiscal does not constitute a judicial authority.

Statutory and Constitutional Provisions

• 1. Article 125, Revised Penal Code: Obligates delivery of an arrested individual to judicial authorities within a specific period.
• 2. Section 1(3), Article III of the 1935 Constitution: Prohibits deprivation of liberty without due process.
• 3. Rule 109, Section 17, Rules of Court: Requires prompt presentation of arrested individuals before a judge.