Umil v. Sese

Summary

Consolidated habeas corpus petitions challenging warrantless arrests of suspected Communist Party/NPA members and other individuals. Supreme Court En Banc denied motions for reconsideration, upholding validity of arrests under Section 5, Rule 113 based on probable cause and good faith. Court applied continuing offense doctrine to subversion cases, distinguishing them from common crimes. Key ruling clarified that mere suspicion is insufficient for warrantless arrest, but actual facts creating probable cause justify detention. Decision emphasized constitutional balance between individual liberty and public order, while maintaining that anti-subversion laws remain valid until legislatively modified. Court reaffirmed that habeas corpus proceedings determine detention legality, not criminal guilt, and stressed prompt judicial review of all warrantless arrests.