In a habeas corpus case involving child custody, the Supreme Court clarified that Regional Trial Courts (RTCs) have jurisdiction within their judicial region, regardless of the child’s or custodian’s specific residence within that region. This ruling means that a petition filed in one city within a judicial region is enforceable in another city within the same region, streamlining legal processes for child custody disputes and ensuring the child’s welfare remains the paramount consideration.

Navigating Jurisdictional Waters: Where Can a Habeas Corpus Petition Be Filed?

The case of Ma. Hazelina A. Tujan-Militante vs. Raquel M. Cada-Deapera revolves around a dispute over the custody of a minor, Criselda M. Cada. The central legal question concerns the jurisdiction of the Regional Trial Court (RTC) in Caloocan City to hear a habeas corpus petition when the minor resides in Quezon City. This issue highlights the complexities of determining proper venue in child custody cases and the enforceability of court orders across different locations within the same judicial region.

The facts of the case are as follows: Raquel M. Cada-Deapera filed a petition for a writ of habeas corpus before the RTC-Caloocan, seeking the return of her daughter, Criselda, from Ma. Hazelina A. Tujan-Militante. The petition indicated several possible addresses for Militante, including one in Caloocan City and another in Quezon City. The RTC-Caloocan issued a writ, but service proved difficult. Subsequently, Militante filed a petition for guardianship in Quezon City, which was later dismissed due to the pending habeas corpus case. Militante then challenged the jurisdiction of the RTC-Caloocan, arguing that she was not properly served and that the court lacked jurisdiction over her and Criselda.

The RTC-Caloocan denied Militante’s motion, citing the principle that service of a writ of habeas corpus confers jurisdiction over the respondent. The Court of Appeals (CA) affirmed this decision, holding that jurisdiction was properly laid and that personal service was valid even if executed outside the city of Caloocan. The appellate court emphasized that the rules on summons in ordinary civil actions do not apply to habeas corpus petitions, which are special proceedings. This legal backdrop sets the stage for the Supreme Court’s intervention to clarify the jurisdictional rules.

The Supreme Court, in its analysis, underscored the importance of Section 20 of A.M. No. 03-04-04-SC, which governs petitions for a writ of habeas corpus involving the custody of minors. This section explicitly states that the writ is enforceable within the judicial region to which the Family Court belongs. The Court quoted the provision:

Section 20. Petition for writ of habeas corpus. – A verified petition for a writ of habeas corpus involving custody of minors shall be filed with the Family Court. The writ shall be enforceable within its judicial region to which the Family Court belongs.

Building on this principle, the Court referenced Section 13 of Batas Pambansa Blg. 129 (BP 129), which defines the judicial regions. The National Capital Judicial Region, as defined by BP 129, includes the cities of Manila, Quezon, Pasay, Caloocan, and Mandaluyong. Given that both Caloocan City and Quezon City fall within the same judicial region, the RTC-Caloocan’s writ could be enforced in Quezon City. This interpretation ensures that the reach of the court’s order extends across the entire region, promoting judicial efficiency and protecting the rights of the child.

A crucial aspect of the Supreme Court’s decision is its clarification regarding the applicability of Section 3 of A.M. No. 03-04-04-SC. Militante argued that the habeas corpus petition should have been filed where she or the minor resided. However, the Court clarified that Section 3 applies exclusively to petitions for custody of minors, not to habeas corpus petitions. The Court emphasized the difference by quoting the provision:

Section 3. Where to file petition. – The petition for custody of minors shall be filed with the Family Court of the province or city where the petitioner resides or where the minor may be found.

This distinction is critical because it limits the application of the residency rule to custody petitions, ensuring that habeas corpus petitions, which demand a more immediate response, can be filed and enforced more broadly within the judicial region. Moreover, the Supreme Court affirmed the appellate court’s stance on the service of summons. Citing Saulo v. Cruz, the Court reiterated that service of a writ of habeas corpus confers jurisdiction over the respondent, functioning similarly to a summons in ordinary civil actions. Thus, the RTC-Caloocan validly acquired jurisdiction over Militante when she was served with the writ, regardless of where the service occurred within the judicial region.

FAQs

What was the key issue in this case?	The central issue was whether the RTC-Caloocan had jurisdiction to hear a habeas corpus petition involving a minor residing in Quezon City. This involved interpreting the rules on venue and enforceability of writs in child custody cases.
What is a writ of habeas corpus?	A writ of habeas corpus is a court order directing a person detaining another to bring the detained person before the court to determine the legality of the detention. In child custody cases, it is used to regain custody of a minor.
What does A.M. No. 03-04-04-SC govern?	A.M. No. 03-04-04-SC provides the Rules on Custody of Minors and Habeas Corpus in Relation to Custody of Minors. It outlines the procedures and jurisdictional rules for these types of cases in the Philippines.
What is the National Capital Judicial Region?	The National Capital Judicial Region includes the cities of Manila, Quezon, Pasay, Caloocan, and Mandaluyong, among others. This region is significant because writs issued by Family Courts are enforceable throughout the entire region.
Does Section 3 of A.M. No. 03-04-04-SC apply to habeas corpus petitions?	No, Section 3 applies only to petitions for custody of minors, not to habeas corpus petitions. This section specifies where to file a custody petition based on the residence of the petitioner or where the minor is found.
Why was the RTC-Caloocan deemed to have jurisdiction in this case?	The RTC-Caloocan had jurisdiction because both Caloocan City and Quezon City are within the same National Capital Judicial Region. The writ issued by the RTC-Caloocan is enforceable throughout this entire judicial region.
Is personal service of summons required in habeas corpus petitions?	No, personal service of summons is not required in habeas corpus petitions. Service of the writ itself confers jurisdiction over the respondent, similar to how a summons works in civil actions.
What is the significance of Batas Pambansa Blg. 129 (BP 129)?	BP 129, also known as the Judiciary Reorganization Act of 1980, defines the judicial regions in the Philippines. It is relevant because it specifies which cities and municipalities are included in the National Capital Judicial Region.

In summary, the Supreme Court’s decision in Tujan-Militante vs. Cada-Deapera clarifies the jurisdictional rules for habeas corpus petitions involving child custody. By emphasizing the enforceability of writs within the judicial region and distinguishing between custody petitions and habeas corpus petitions, the Court provides clearer guidelines for legal practitioners and ensures the swift resolution of child custody disputes.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Tujan-Militante vs. Cada-Deapera, G.R. No. 210636, July 28, 2014