FACTS:
Petitioner, an American, and respondent, a Filipino, were married and had a daughter. However, respondent grew restless and bored as a housewife and left the family home with their daughter without notifying petitioner. Petitioner filed a petition for habeas corpus in the designated Family Court in Makati City, but it was dismissed. Petitioner then went to Basilan to search for them but was unsuccessful. He filed another petition for habeas corpus in the Court of Appeals, which was denied on the ground of lack of jurisdiction. The Court of Appeals ruled that the Family Courts have exclusive jurisdiction over petitions for habeas corpus. Petitioner argues that this would allow a respondent to easily evade the service of a writ of habeas corpus by moving out of the region over which the Regional Trial Court issuing the writ has territorial jurisdiction. The Solicitor General points out that a rule rendered this issue moot. The Supreme Court granted the petition, ruling that the Court of Appeals still has jurisdiction over the case.
ISSUES:
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Whether the Court of Appeals has jurisdiction to issue writs of habeas corpus in cases involving custody of minors.
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Whether RA 8369 impliedly repealed RA 7902 and BP 129.
RULING:
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The Court of Appeals has jurisdiction to issue writs of habeas corpus in cases involving custody of minors. The Court held that there is nothing in RA 8369 that revoked the jurisdiction of the Court of Appeals to issue writs of habeas corpus involving the custody of minors.
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RA 8369 did not impliedly repeal RA 7902 and BP 129. The Court disagreed with the Court of Appeals' reasoning that the word "exclusive" in RA 8369 can only be construed to mean that family courts are the sole courts that can issue writs of habeas corpus. The Court emphasized that such interpretation would leave individuals without legal recourse in obtaining custody of their children, which could not have been the intention of the lawmakers when they passed the Family Courts Act of 1997.
PRINCIPLES:
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Jurisdiction is conferred by law. A court cannot exercise jurisdiction that is not conferred upon it, even if it is demanded by expediency or necessity.
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The enactment of a law on jurisdiction is within the exclusive domain of the legislature. The remedy for perceived defects in the law is to be sought from the legislature, not the courts.
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In interpreting laws, the court should avoid an interpretation that would lead to absurd or iniquitous consequences. The intent of the lawmakers should be given weight, and the interpretation should promote justice and the protection of rights.