Velasco v. Court of Appeals

Summary

Lawrence Larkins was arrested without warrant by NBI investigators for rape based on complainant's affidavit. Though he had posted bail for separate BP 22 cases and court ordered his release, NBI continued detention for rape investigation. When formal rape complaint was filed and trial court denied his bail application and motion to dismiss, his common-law wife filed habeas corpus petition. Court of Appeals granted the writ, ordering his release on ground that warrantless arrest was illegal and no criminal complaint existed when detention began. Supreme Court reversed, ruling that even if initial arrest was illegal, detention became legal due to supervening events: filing of criminal complaint, court's denial order constituting judicial process, and accused's voluntary submission to jurisdiction by filing bail motion. Court emphasized that habeas corpus is unavailable once person is charged with an offense, and that judicial processes issued by competent courts justify continued detention regardless of initial illegality.