**Facts:**
1. **Initial Charge and Arrest:**
– Michael Labrador Abellana (Petitioner) was charged at Branch 13, RTC Cebu City for violation of Sections 11 and 12, Article II of R.A. 9165 (Comprehensive Dangerous Drugs Act).
– On May 26, 2008, during a police search led by P/Supt. Labra at his residence in Bgy. Suba, Cebu City, shabu and related paraphernalia were found. Petitioner was charged under criminal information CBU-77150 and CBU-77151 for possession of shabu and paraphernalia.
2. **Pleadings and Motions Filed:**
– Petitioner pled not guilty.
– Filed a Motion to Quash Search Warrant (denied on September 15, 2006).
– Filed a Motion for Physical Re-examination and Re-weighing of Evidence (granted, revealing lesser weight of shabu).
– Filed a Petition for Bail (granted, leading to his temporary release).
3. **Trial Proceedings:**
– Represented by Atty. Dario Rama, Jr. initially.
– Filed a demurrer to evidence (denied).
– Atty. Raul Albura entered appearance on December 3, 2008.
– Case submitted for decision on April 30, 2009, due to failure to present defense evidence.
– Filed an Urgent Motion to Defer Promulgation of Judgment (denied).
4. **Conviction and Post-Conviction Motions:**
– Convicted on July 29, 2009, with various sentences for both charges.
– Filed a Motion for New Trial or Reconsideration (denied, arrest warrant issued).
– Petition for Relief from Judgment filed (denied as improper remedy and untimely).
5. **Court of Appeals:**
– CA dismissed the certiorari petition affirming RTC’s decisions on procedural grounds.
6. **Petition for Habeas Corpus:**
– Filed on June 20, 2017, claiming deprivation of constitutional rights to due process and competent counsel.
**Issues:**
1. **Whether there was a deprivation of Constitutional rights sufficient to warrant the writ of habeas corpus.**
2. **Whether the petitioner was denied due process during the RTC proceedings.**
3. **Whether petitioner was denied his right to competent counsel.**
**Court’s Decision:**
1. **Habeas Corpus Petition:**
– Determined not applicable as petitioner’s detention stemmed from a judicially rendered decision.
– Writ may only be availed under exceptional circumstances which petitioner failed to meet.
2. **Right to Due Process:**
– Court ruled petitioner was given multiple opportunities to be heard but failed to attend crucial hearings by choice or due negligence.
– The hearing on April 30, 2009 was procedurally appropriate and notice was established through various channels including counsel and bondsman.
3. **Right to Competent Counsel:**
– Even assuming counsel’s negligence, petitioner did not demonstrate the grossly negligent conduct sufficient to nullify proceedings.
– Petitioner himself was partly negligent for not attending and monitoring case developments.
**Doctrine:**
– **Habeas Corpus Post-Conviction Remedy:** The writ is only applicable under exceptional circumstances like violations resulting in void proceedings—deprivation of constitutional rights, lack of jurisdiction, or excessive penalty.
– **Due Process in Judicial Proceedings:** Opportunity to be heard equals due process—actual participation is not mandatory if opportunities exist and are ignored.
– **Competent Counsel Rule:** Clients are generally bound by their counsel’s actions unless there is gross negligence accompanied by client’s due diligence, both of which were missing here.
**Class Notes:**
1. **Habeas Corpus:** Remedy for illegal detention unless stemming from valid court proceedings.
2. **Due Process:** Procedural fairness equated to opportunities, not necessarily actual participation.
3. **Competent Counsel:** Client responsibility alongside counsel. No resetting cases based solely on the counsel’s procedural lapses without client vigilance.
**Historical Background:**
– Context of R.A. 9165 enforcement showing tougher stances on drug-related offenses.
– Emphasizes judiciary’s role in balancing rigorous law enforcement with safeguarding procedural rights.
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