#### Facts:
Norberto Feria y Pacquing was convicted for the crime of Robbery with Homicide in 1985 by the Regional Trial Court (RTC) of Manila, Branch 2. His conviction resulted from a robbery and the killing of a United States Peace Corps Volunteer named Margaret Viviene Carmona in 1981. Years after his conviction, a fire in 1986 at the Manila City Hall destroyed the records of his case. In 1993, Feria sought transfer from the Manila City Jail to the Bureau of Corrections in Muntinlupa, which revealed the loss of the case records. Unable to effect the transfer without the commitment order or mittimus, decision, and information, the situation prompted Feria to file a petition for the issuance of a Writ of Habeas Corpus in 1994 to secure his release, claiming illegal detention as the records of his conviction were missing. The Supreme Court issued the writ and ordered an immediate raffle and hearing. The RTC of Manila, Branch 9 dismissed the habeas corpus petition, a decision later affirmed by the Court of Appeals, prompting Feria to elevate the case to the Supreme Court on certiorari.
#### Issues:
1. **Legality of Incarceration:** Whether the absence of records due to their loss justifies continued incarceration under the law.
2. **Basis of Incarceration:** Whether the resolution by the Court of Appeals affirming the denial of Feria’s habeas corpus petition serves as a lawful basis for incarceration.
3. **Initiation of Record Reconstitution:** Whether reconstitution of lost or destroyed official records should be initiated by the government or the prisoner.
#### Court’s Decision:
The Supreme Court denied the petition, sustaining the appellate court’s decision. The Court held that the mere loss of records does not render a judgment of conviction void nor justify the release of the convict. The factual foundations of Feria’s conviction were established, including his own admissions and the judicial findings of his conviction and sentence to life imprisonment. The Court reiterated that habeas corpus proceedings examine the legality of detention, not the loss of records, and the evidence was sufficient to uphold the legality of Feria’s detention.
#### Doctrine:
– The proper remedy for the loss or destruction of judicial records post-conviction is their reconstitution, a duty shared by both prosecution and defense.
– A conviction by a court with jurisdiction, evidenced through sufficient documentary and admission records, validates the continued incarceration of a prisoner despite the physical loss of the court’s records.
#### Class Notes:
– **Fundamental Rights and Habeas Corpus:** Habeas Corpus serves as a mechanism to examine unlawful detention, ensuring the legality of the basis of imprisonment.
– **Reconstitution of Records:** The law provides for the reconstitution of judicial records lost due to unforeseen circumstances, emphasizing the shared responsibility between defense and prosecution.
– **Judicial Admissions:** Statements made by a defendant regarding material facts of a case are admissible against them, forming part of the evidence for or against their claims.
#### Historical Background:
This case illustrates the procedural challenges faced in the Philippine judiciary when physical records are destroyed due to calamities. It underscores the importance of maintaining accurate judicial records and highlights the procedural mechanisms in place for addressing the loss of such documents, ensuring that justice prevails even when administrative obstacles arise.
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