1) Three police officers were convicted but later acquitted of murdering two individuals based on reasonable doubt. Another police officer later confessed and implicated the petitioners. Warrants for the petitioners' arrest were issued.
2) The petitioners filed a motion to quash the arrest warrants without surrendering. The motion was denied for lack of jurisdiction since the petitioners were not in custody. An appeal overturned this decision.
3) The Supreme Court upheld allowing special appearances like the motion to quash without requiring custody. Jurisdiction over a person and custody are distinct, and due process demands liberty not be deprived without opportunity to assert it.
1) Three police officers were convicted but later acquitted of murdering two individuals based on reasonable doubt. Another police officer later confessed and implicated the petitioners. Warrants for the petitioners' arrest were issued.
2) The petitioners filed a motion to quash the arrest warrants without surrendering. The motion was denied for lack of jurisdiction since the petitioners were not in custody. An appeal overturned this decision.
3) The Supreme Court upheld allowing special appearances like the motion to quash without requiring custody. Jurisdiction over a person and custody are distinct, and due process demands liberty not be deprived without opportunity to assert it.
1) Three police officers were convicted but later acquitted of murdering two individuals based on reasonable doubt. Another police officer later confessed and implicated the petitioners. Warrants for the petitioners' arrest were issued.
2) The petitioners filed a motion to quash the arrest warrants without surrendering. The motion was denied for lack of jurisdiction since the petitioners were not in custody. An appeal overturned this decision.
3) The Supreme Court upheld allowing special appearances like the motion to quash without requiring custody. Jurisdiction over a person and custody are distinct, and due process demands liberty not be deprived without opportunity to assert it.
01) Miranda v. Tuliao, G.R. No. 158763, March 31, 2006 (7) Dec. 2002: CA granted the petition and ordered the reinstatement of the criminal Chico-Nazario, J. cases in the RTC, as well as the issuance of warrants of arrest against petitioners and SPO2 Maderal. CA held that jurisdiction over the person of the accused may be RECIT READY: In this case, petitioners filed an urgent motion to complete preliminary acquired either through compulsory process, such as warrant of arrest, or through investigation, to reinvestigate and to quash the warrants of arrest; however, it was voluntary appearance, such as when he surrenders to the police or to the court. Since denied by Judge Tumaliuan on the ground that the court did not acquire jurisdiction the petitioners were not yet arrested nor deprived of their liberty at the time they over their persons since they were absent. Hence, the motion cannot be properly filed their “Urgent Motion to complete preliminary investigation, to reinvestigate heard. This was reversed by Judge Anghad but was eventually reinstated by the CA. and to quash the warrants of arrest”, they cannot seek any judicial relief. (8) Hence this petition. Petitioners argue that jurisdiction over the person of the accused The SC held that the accused can seek judicial relief because jurisdiction over their is required only in applications for bail. Nevertheless, jurisdiction over their person person nor custody of the law over their body is not required in the adjudication of was acquired by their filing of the Urgent Motion. a motion to quash a warrant of arrest. It is a case of special appearance. ISSUE/S: WON the accused cannot seek any judicial relief if he does not submit his person to DOCTRINE: Adjudication of a motion to quash a warrant of arrest requires neither the jurisdiction of the court. jurisdiction over the person of the accused, nor custody of law over the body of the accused. HELD: NO. HE CAN SEEK JUDICIAL RELIEF. Doctrine: Adjudication of a motion to quash a warrant of arrest requires neither jurisdiction (1) FACTS: March 8, 1996: Two burnt cadavers identified as the dead bodies of Vicente over the person of the accused, nor custody of law over the body of the accused. Bauzon and Elizer Tuliao (son of private respondent Virgilio Tuliao) were discovered in Purok Nibulan, Ramon, Isabela. First, the Court distinguished custody of law from jurisdiction over the person of accused. (2) Two informations for murder were filed against SPO1 Wilfredo Leaño, SPO1 Custody of the law is accomplished either by arrest or voluntary surrender, while jurisdiction Ferdinand Marzan, SPO1 Ruben B. Agustin, SPO2 Alexander Micu, SPO2 Rodel over the person of the accused is acquired upon his arrest or voluntary appearance. One can Maderal, and SPO4 Emilio Ramirez in the Regional Trial Court (RTC). They were be under the custody of the law but not yet subject to the jurisdiction of the court over his convicted but acquitted on appeal due to reasonable doubt. person, such as when a person arrested by virtue of a warrant files a motion before (3) Sometime in September 1999: SPO2 Maderal was arrested. On April 27, 2001: SPO2 arraignment to quash the warrant. On the other hand, one can be subject to the jurisdiction Maderal executed a sworn confession and identified petitioners Jose C. Miranda, of the court over his person, and yet not be in the custody of the law, such as when an accused SPO3 Alberto P. Dalmacio, PO3 Romeo B. Ocon, a certain Boyet dela Cruz and Amado escapes custody after his trial has commenced. Doe, as the persons responsible for the deaths of Vicente Bauzon and Elizer Tuliao. Respondent Virgilio filed a criminal complaint for murder against the 5 identified In Pico v. Judge Combong, Jr.: Insofar as it concerns bail, the general rule is that one who seeks individuals and submitted Maderal’s sworn confession. Warrants of arrest were an affirmative relief is deemed to have submitted to the jurisdiction of the court. An exception issued. to the rule that filing pleadings constitute voluntary appearance is the case of pleadings whose (4) June 2001: Petitioners filed an urgent motion to complete preliminary investigation, prayer is for the avoidance of the jurisdiction of the court, which only leads to a special to reinvestigate and to quash the warrants of arrest. Judge Tumaliuan noted the appearance. These pleadings in criminal cases are: motions to quash a complaint on the absence of petitioners and DENIED the motion on the ground that since the court ground of lack of jurisdiction over the person of the accused; and motions to quash a warrant did not acquire jurisdiction over their persons, the motion cannot be properly heard of arrest. by the court. (5) Petitioners appealed the resolution of State Prosecutor Reyes to the Dept. of Justice. Therefore, in cases involving special appearances, an accused can invoke the processes of the On August 2001: the new Presiding Judge Anastacio Anghad took over the case and court even though there is neither jurisdiction over the person nor custody of the law. reversed the order of Judge Tumaliuan, whereby he cancelled the warrant of arrest However, if a person invoking the special jurisdiction of the court applies for bail, he must first issued against the 3 petitioners of this case. submit himself to the custody of the law. (6) Oct. 2001: Tuliao filed a petition for certiorari, mandamus and prohibition to this Court, with prayer for TRO, seeking to enjoin Judge Anghad from further proceeding As much as it is incongruous to grant bail to one who is free, it is likewise incongruous to require with the case and to nullify his orders. TRO was granted. However, Judge Anghad still one to surrender his freedom before asserting it. Human rights enjoy a higher preference in issued a joint order dismissing the two Information for murder against petitioners. the hierarchy of rights than property rights, demanding that due process in the deprivation of Due to this, Tuliao filed a motion to cite public respondent in contempt. liberty must come before its taking and not after.