Facts:

This case revolves around Petitioner Victorio Aleria, Jr., who is facing serious criminal charges in Criminal Case No. 95-394 for Illegal Possession of Firearms, and Criminal Case No. 95-395 for Murder, both stemming from a single incident that occurred on January 9, 1995. The cases are being jointly tried in the Regional Trial Court (RTC), Branch 20, of Cagayan de Oro City, presided over by Hon. Alejandro M. Velez. On July 17, 1995, Aleria filed a Petition to Admit Bail, seeking bail for the firearms charge, which was set at P300,000.00, while no bail was recommended for the murder charge. Subsequent to hearings on the petition, Judge Velez issued an order on July 19, 1996, denying the bail request on the ground that the prosecution had established strong evidence against Aleria. The order itself lacked a detailed account of the evidence presented during the hearings.

In response to this denial, Aleria filed a Motion for Reconsideration on August 7, 1996, contending that the Ju

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Facts:

Overview of the Case

• Petitioner Victorio Aleria, Jr. is charged in two criminal cases stemming from the same incident:
• Criminal Case No. 95-394 for Illegal Possession of Firearms
• Criminal Case No. 95-395 for Murder
• Both cases are tried jointly by the same trial court, headed by respondent Judge Alejandro M. Velez in his official capacity.

Bail Petition and Initial Orders

• On July 17, 1995, petitioner filed a Petition to Admit Bail in both cases:
• In Criminal Case No. 95-394, a recommended bail amount of ₱300,000.00 was proposed.
• In Criminal Case No. 95-395, no bail recommendation was made.
• The trial court conducted bail hearings wherein both the prosecution and the petitioner presented their memoranda on the bail petition.
• On July 19, 1996, the trial court issued an Order denying bail based on:
• The evidence submitted by the prosecution which the court deemed sufficiently strong to sustain the charges against petitioner.
• A lack of convincing evidence to rebut the prosecution’s case, leading to the conclusion that the petitioner was criminally liable.

Motion for Reconsideration and Subsequent Order

• Accused filed a Motion for Reconsideration on August 7, 1996, arguing that:
• The Order denying bail was not adequately supported by the evidence on record.
• The Order lacked a clear statement of the grounds for denial and did not specify the evidence used to establish that the evidence of guilt was strong.
• On September 2, 1996, the trial court issued an Order denying the Motion for Reconsideration, stating:
• Its previous denial was based on a summary evaluation of the evidence (including the circumstances surrounding the victim’s death, the presence of the accused with the victim, and the presentation of the firearm).
• There is no statutory or jurisprudential requirement to adhere to a fixed formula; rather, the judge’s sound discretion was exercised.

Petition for Certiorari, Inhibition, and Temporary Restraining Order

• Petitioner elevated the issue by filing a petition for certiorari with an accompanying prayer for:
• Inhibition of respondent Judge from further handling the case, alleging bias or loss of impartiality.
• Issuance of a temporary restraining order to allow the petitioner to post bail in an amount reasonably affordable.
• The petition challenged the validity of both Orders (dated July 19, 1996 and September 2, 1996), arguing that:
• The Orders were defective because they did not include a summary of the evidence against the petitioner.
• The absence of a detailed evidentiary summary breached the principles of judicial due process.

Comments and Manifestations by the Parties

• On January 15, 1997, the Court directed respondents to comment on the petition.
• On February 13, 1997, the prosecution filed a Comment emphasizing that the trial court had clearly stated the basis for denying bail.
• On June 6, 1997, the Office of the Solicitor-General filed a Manifestation and Motion (in lieu of Comment) contending that:
• The two Orders were defective in form and substance for failing to include a summary of the prosecution’s evidence.
• The respondent Judge should be directed to issue a revised order that properly articulates the evidence and the conclusion on the strength of the evidence.
• On July 11, 1997, petitioner filed a Manifestation with Motion reiterating the request for a conclusive resolution on the bail petition and contesting the recommendation of the Office of the Solicitor-General concerning the procedural posture of the case.

Legal and Constitutional Context

• The constitutional provision ensures that all persons (with the exception of those charged with certain capital offenses when evidence is strong) are bailable pending conviction.
• Petitioner is charged with a capital offense (Murder), punishable by reclusion perpetua or death, which at the time of the arrest, was subject to the rule that bail may be denied if the evidence of guilt is strong.
• The determination of whether the evidence of guilt is strong is a matter of judicial discretion, though subject to procedural mandates such as providing a summary of the evidence.

Issue:

Validity and Procedural Adequacy of the Bail Orders

• Whether the trial court’s Orders denying bail (dated July 19, 1996 and September 2, 1996) are legally valid given that they did not include a detailed summary of the evidence presented by the prosecution.
• Whether the omission in the Orders violates the constitutional mandate and judicial due process by failing to articulate the factual basis for determining that the evidence of guilt is strong.

Exercise of Judicial Discretion

• Whether the trial court properly exercised its sound discretion in evaluating the evidence in the criminal cases, particularly in cases involving a capital offense.
• Whether the absence of a detailed evidentiary summary in the denial of bail substantially undermines the application of judicial discretion.

Issue of Judicial Impartiality and Inhibition

• Whether the issuance of the contested Orders implies that respondent Judge has already lost his impartiality in handling the case.
• Whether petitioner is entitled to an order for inhibition of respondent Judge under the grounds of alleged bias and lack of neutrality.

Proper Forum for Review

• Whether the Supreme Court has jurisdiction to review the matter of denial of bail amidst the existence of a parallel remedy in the Court of Appeals.
• Whether the filing of a petition for certiorari, in this context, undermines the hierarchical and jurisdictional protocols between the trial courts, Court of Appeals, and the Supreme Court.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)