G.R. No. 85140. May 17, 1990 (Case Brief / Digest)

### Title
Tomas Eugenio, Sr. vs. Hon. Alejandro M. Velez, et al.

### Facts
In 1987, Vitaliana Vargas was allegedly confined by Tomas Eugenio in his residence in Misamis Oriental, Philippines. After her death on August 28, 1988, Vitaliana’s siblings filed a habeas corpus petition in September 1988, being unaware of her passing, to recover her from Eugenio. The petition led to a series of legal motions, including the issuance of a writ of habeas corpus, orders for the delivery of Vitaliana’s body for autopsy, and subsequent amendments to recognize Vitaliana’s death and argue over the custody of her remains. Eugenio, claiming to be her common-law husband, insisted on his right to custody for burial according to the rites of a religious sect he led. Contestations from both sides on the jurisdiction of the Regional Trial Court (RTC) and the nature of the proceeding led to the escalation of the case to the Philippine Supreme Court.

### Issues
1. Whether habeas corpus proceedings can apply to the case of a deceased individual.
2. The jurisdiction of the RTC over proceedings initially filed as habeas corpus but transitioned into a question of custody over a dead body.
3. Interpretation and application of the right to custody of a deceased’s remains in the absence of a legally recognized spouse.

### Court’s Decision
The Philippine Supreme Court dismissed the petitions, affirming the decision of the lower court. It ruled that:
1. The petition for habeas corpus became moot and academic after Vitaliana’s death was confirmed. However, the amendment to address the custody of her remains was acceptable to prevent multiplicity of lawsuits.
2. The RTC had the jurisdiction to decide on the matter as it involved the custody and burial of the deceased, per Batas Pambansa Blg. 129 and relevant provisions of the Civil Code.
3. Eugenio, being a common-law husband with a subsisting marriage elsewhere, did not have legal standing to the custody of Vitaliana’s body over her nearest kin – her siblings. The Court clarified that Philippine law does not recognize common-law marriages in the way intended by Eugenio for claims of custody.

### Doctrine
– A habeas corpus proceeding becomes moot and academic upon the death of the subject individual, but jurisdiction over the case may continue to address subsequent legal matters arising from the case, such as custody of the deceased’s body.
– The term “spouse” in legal provisions refers to a lawfully wedded spouse, excluding common-law relationships from legal claims that presuppose a lawful marriage.

### Class Notes
**Key Concepts:**
– **Habeas Corpus:** Primarily for addressing illegal detentions. Not applicable posthumously.
– **Jurisdiction of the RTC:** Extends to cases not specified but by nature within its purview, including custody disputes over deceased’s remains.
– **Legal Custody of Deceased Remains:** Governed by statutory and common law preferences – marital status prevails, but common-law partnerships recognized under certain contexts do not extend to custodial claims over remains.
– **Common-Law Relationships:** Not equated with legal marriage in the Philippines, especially for custody and inheritance disputes.

**Relevant Statutes:**
– **Batas Pambansa Blg. 129:** Defines the jurisdiction of the RTC.
– **Civil Code Articles 294, 305, and 308:** Outline the support hierarchy and rights to funeral arrangements, explicitly prioritizing legally recognized relationships.

### Historical Background
The case embodies the legal challenge of reconciling contemporary societal practices, such as common-law living arrangements, with the Philippines’ codified laws that have yet to fully recognize such social realities in certain legal disputes, notably in matters of custody over deceased individuals’ remains. It showcases the interplay between societal changes, legal recognition, and the safeguarding of traditional familial rights in the context of Philippine jurisprudence.


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