Medina v. Orozco
G.R. No. L-26723, December 22,  1966

FACTS: November 7, 1965, petitioner Arthur Medina was arrested and thereafter incarcerated in the Caloocan City jail, allegedly as one of those responsible for the death of one Marcelo Sangalang which occurred on October 31, 1965 in said city. At about 9:00 o'clock in the morning of the same day, November 7, 1965, the case against Medina and two others for Sangalang's murder was referred to a fiscal, who forthwith conducted a preliminary investigation in petitioner's presence. At about 3:40 p.m. on November 10, 1965, an information for murder was filed against petitioner Arthur Medina, and Antonio Olivar and Alexander Enriquez in the Caloocan branch of the Court of First Instance of Rizal. By court order, they were promptly committed to jail.  
Petitioner claims violation of Article 125 of the Revised Penal Code. The crime — for which petitioner is detained — is murder, a capital offense. The arresting officer's duty under the law1 was either to deliver him to the proper judicial authorities within 18 hours, or thereafter release him. The fact however is that he was not released. From the time of petitioner's arrest at 12:00 o'clock p.m. on November 7 to 3:40 p.m. on November 10 when the information against him for murder actually was in court, over 75 hours have elapsed. But, stock should be taken of the fact that November 7 was a Sunday; November 8 was declared an official holiday; and November 9 (election day) was also an official holiday.

ISSUE: WON the authorities are liable for arbitrary detention.

HOLDING: NO. The SC ruled that in these three no-office days, it was not an easy matter for a fiscal to look for his clerk and stenographer, draft the information and search for the Judge to have him act thereon, and get the clerk of court to open the courthouse, docket the case and have the order of commitment prepared. And then, where to locate and the certainty of locating those officers and employees could very well compound the fiscal's difficulties. These are considerations sufficient enough to deter the court from declaring that Arthur Medina was arbitrarily detained. For, he was brought to court on the very first office day following arrest.
               Petitioner is jailed because of the court's order of commitment of November 10, 1965 upon a murder indictment. No bail was provided for him, because he is charged with a capital offense. Such detention remains unaffected by the alleged previous arbitrary detention. Because, detention under a valid information is one thing, arbitrary detention anterior thereto another. They are separate concepts. Simply because at the inception detention was wrong is no reason for letting petitioner go scot-free after the serious charge of murder has been clamped upon him and his detention ordered by the court. The first is illegal; but the second is not.

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