Eduardo Dizon and Isabel Ramos had been arrested by the military, detained in the military camp, and then claimed by the military to have been released after nine days. The two were arrested by the Philippine Constabulary of Pampanga then led by respondent Provincial Commander Col. Teddy Carian, without a warrant of arrest or a Presidential Order of Arrest. They were detained by the respondents at the PC Stockade under the jurisdiction of respondents Brig. Gen. Vicente Eduardo, then Regional Commander of the area, and Col. Teddy Carian for interrogation and investigation without assistance of counsel. However, they were not released to their parents, who had been visiting them, and were never seen or heard from by anyone since then. This led to the application for the issuance of a writ of habeas corpus by the petitioners, Juan Dizon and Soledad Ramos.

The Court did not grant the petition; and instead, ordered the reinvestigation by the CHR. This is because the general rule in a writ of habeas corpus proceeding is that the release of a detained person renders the petition for habeas corpus moot and academic. If the release is an established fact and not in dispute, they do not continue to be missing persons or desaparecidos. Where, however, there are grounds for grave doubts about the alleged release, where the standard and prescribed procedure in effecting the release has not been followed, then the burden of proving by clear and convincing evidence the alleged release is shifted to the respondents. Release is an affirmative defense and "each party must prove his own affirmative allegations," just as the burden of proof of self-defense in a killing rests on the accused. Moreover, evidence of release lies particularly within respondents' power.

In this case, however, the facts were insufficient to prove any irregularities. As a consequence, the case must be referred to the CHR for a reinvestigation. The Supreme Court is not a trier of facts, nor does it have the means and facilities to conduct such investigation of the grave charges at bar as well as of the whereabouts of the desaparecidos. Moreover, the 1987 Constitution which was overwhelmingly ratified on February 2,1987 expressly mandated the creation of the Commission on Human Rights. The Constitution vested the Commission on Human Rights with broader powers than its predecessor committee, such as to investigate, on its own or on complaint by any party, all forms of human rights violations involving civil and political rights. Thus, the referral to the CHR was in order.