Nghia v. Liwag

Summary

French national Lucien Tran Van Nghia filed habeas corpus petition challenging his warrantless arrest and detention by Immigration Commissioner for deportation proceedings. Petitioner argued 1987 Constitution requires judicial determination of probable cause for arrest warrants. Supreme Court dismissed petition as moot and academic, finding petitioner was released on standard bailbond without restrictive conditions and formal deportation proceedings had commenced, making any restraint legal. Court distinguished case from Harvey precedent, noting absence of probable cause in initial arrest, but ruled supervening events cured any defects. Case establishes that habeas corpus becomes moot upon release unless accompanied by conditions restricting freedom of movement, and that formal deportation proceedings legitimize administrative detention.