FACTS:

Anita Mangila and four others were charged with syndicated estafa and violations of Republic Act No. 8042 in the Municipal Trial Court in Cities in Puerto Princesa City. The charges arose from their recruitment of private complainants as overseas contract workers in Canada, as well as the collection of fees without authority from the Philippine Overseas Employment Administration. Judge Heriberto M. Pangilinan conducted a preliminary investigation and issued a warrant for the arrest of Mangila and her cohorts without bail. Mangila was arrested and detained at the National Bureau of Investigation. Claiming that the preliminary investigation and the issuance of the warrant were invalid, Mangila filed a petition for habeas corpus in the Court of Appeals (CA) seeking her release from detention. The CA denied the petition, stating that Mangila should have filed a motion to quash the warrant or a motion for reinvestigation with the Provincial Prosecutor. Mangila's motion for reconsideration was also denied. Mangila then appealed via petition for review on certiorari.

ISSUES:

1. Did the Court of Appeals err in ruling that habeas corpus was not the proper remedy to obtain the release of Mangila from detention?

RULING:

1. The petition for review lacks merit. Habeas corpus is not the proper remedy to obtain the release of Mangila from detention. The Court explained that habeas corpus is a special proceeding intended to inquire into the right of liberty and provide relief from unlawful restraint. It cannot be used to inquire into the criminal act or to review errors of law or irregularities not involving jurisdiction. Furthermore, habeas corpus should not be granted in advance of trial and cannot be used when the restraint is under legal process. The proper remedy in this case is for Mangila to file a motion to be released from detention with the Provincial Prosecutor, based on the grounds alleged in her habeas corpus petition.

PRINCIPLES:

• Habeas corpus is a special proceeding governed by Rule 102 of the Rules of Court. It seeks the enforcement of civil rights and relief from illegal restraint. It cannot be used to inquire into the criminal act or review errors of law or irregularities not involving jurisdiction.

• Habeas corpus should not be granted in advance of trial and cannot be used when the restraint is under legal process.

• The proper remedy when detained under legal process is to file a motion for release from detention with the appropriate authority.