SPECIAL PROCEEDINGS | Harden v. Director of Prisons, 81 Phil. 741, October 22, 1948

Harden v. Director of Prisons, 

81 Phil. 741, October 22, 1948


FACTS The petitioner, Fred M. Harden, is being confined in prison for contempt of court. This case revolves around the petition for habeas corpus filed by Mr. Harden, who was detained in the New Bilibid Prison in the Philippines. Mr. Harden claimed that his continued detention was illegal and sought relief from the court. Whether the petitioner's detention was in violation of his fundamental or constitutional rights and, therefore, warranted relief through a writ of habeas corpus; and Whether or not in truth the court’s findings are supported by sufficient evidence.


HELD Broadly speaking, the grounds for relief by habeas corpus are only (1) deprivation of any fundamental or constitutional rights, (2) lack of jurisdiction of the court to impose the sentence, or (3) excessive penalty.” 


Here, the court thoroughly examined the circumstances surrounding Mr. Harden's detention and concluded that none of the grounds for relief were present. The court found that Mr. Harden's detention did not violate his fundamental or constitutional rights, the court had proper jurisdiction to impose the sentence, and the penalty imposed was not excessive. The punishment meted out to the petitioner is not excessive, It is suitable and. adapted to its objective; and it accords with section 7, Rule 64, of the Rules of Court which provides that “When the contempt consists in the omission to do an act which is yet in the power of the accused to perform, he may be imprisoned by order of a superior court until he performs it.” If the term of imprisonment in this case is indefinite and might last through the natural life of the petitioner, yet by the terms of the sentence the way is left open for him to avoid serving any part of it by complying with the orders of the court, and in this manner put an end to his incarceration. In these circumstances, the judgment can not be said to be excessive or unjust.


No on the second issue. Whether or not in truth the court’s findings are supported by sufficient evidence is a different matter; it is a matter of fact which can not be reviewed by habeas corpus. In a long line of decisions, this court has steadfastly held that habeas corpus does not He to correct errors of fact or law. When a court has jurisdiction of the offense charged and of the party who is so charged, its judgment, order or decree is not subject to collateral attack by habeas corpus. The writ of. habeas corpus can not be made to perform the function of a. writ of error; and this holds true even if the judgment, order or decree was erroneous, provided it is within the jurisdiction of the court which rendered such judgment or issued such an order or decree.








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