Case Digest (G.R. No. 252117)
Facts:
This case, In the Matter of the Urgent Petition for the Release of Prisoners on Humanitarian Grounds in the Midst of the COVID-19 Pandemic (G.R. No. 252117, July 28, 2020), involved 22 petitioners namely Dionisio S. Almonte, Ireneo O. Atadero, Jr., Alexander Ramonita K. Birondo, Winona Marie O. Birondo, Rey Claro Casambre, Ferdinand T. Castillo, Francisco Fernandez, Jr., Renante Gamara, Vicente P. Ladlad, Ediesel R. Legaspi, Cleofe Lagtapon, Ge-ann Perez, Adelberto A. Silva, Alberto L. Villamor, Virginia B. Villamor, Oscar Belleza, Norberto A. Murillo, Reina Mae Nasino, Dario Tomada, Emmanuel Bacarra, Oliver B. Rosales, and Lilia Bucatcat. The petitioners were persons deprived of liberty (PDLs) detained in various detention facilities, including the Metro Manila District Jail 4 (MMDJ4), Taguig City Jail Female Dorm, Manila City Jail, and Correctional Institution for Women (CIW), Mandaluyong City. They claimed to belong to vulnerable groups due to old age, health conditions like
Case Digest (G.R. No. 252117)
Facts:
- Background and Petitioners' Allegations
- Amid the COVID-19 pandemic, a group of 22 petitioners—detained persons mostly elderly, sick, or pregnant—filed a petition before the Supreme Court seeking their release on humanitarian grounds. They alleged that detention centers are overcrowded and conditions make compliance with health protocols impossible, increasing their susceptibility to infection.
- Petitioners sought:
- Temporary liberty on recognizance or bail during the public health emergency.
- The creation of a Prisoner Release Committee to study and implement the release of others similarly situated.
- Issuance of ground rules for the conditional release of eligible prisoners.
- Petitioners invoked equity jurisdiction and cited international instruments such as the Revised United Nations Standard Minimum Rules for the Treatment of Prisoners (Nelson Mandela Rules) and the International Covenant on Civil and Political Rights (ICCPR).
- Respondents' Opposition
- The Office of the Solicitor General (OSG) opposed the petition, arguing among others that:
- Petitioners belong to the Communist Party of the Philippines-New People’s Army-National Democratic Front (CPP-NPA-NDF) and are charged with heinous crimes.
- Government has undertook sufficient medical precautions and implemented measures to address COVID-19 in jails.
- Petitioners failed to observe the doctrine of hierarchy of courts by filing directly with the Supreme Court instead of trial courts.
- Bail in cases involving offenses punishable by reclusion perpetua is discretionary after a proper hearing to determine strength of evidence, which petitioners failed to avail before trial courts.
- The grant or denial of bail is a factual inquiry for trial courts, not for the Supreme Court.
- The requested creation of a Prisoner Release Committee is a policy matter beyond the Court’s power.
- The release would violate equal protection as all detainees face similar risk.
- The Philippines as a sovereign state is not bound to adopt jail release strategies of foreign jurisdictions.
- Jail Conditions and COVID-19 Context
- The Philippines has long-standing issues of jail overcrowding with occupancy rates exceeding 300-400% in various facilities, especially New Bilibid Prison and district jails.
- COVID-19 is a highly contagious virus causing respiratory illness, with certain groups (elderly, sick, pregnant) susceptible to severe infection.
- Social distancing and self-isolation—key preventive measures—are practically impossible inside congested jails.
- The Bureau of Jail Management and Penology (BJMP) and Bureau of Corrections (BuCor) reported various measures such as lockdowns, isolation facilities, use of personal protective equipment, and temporary suspension of jail visitations.
- The Court took judicial notice of the pandemic and jail conditions, recognizing the extraordinary context.
Issues:
- Whether the petition directly filed with the Supreme Court for provisional release on humanitarian grounds may be given due course in view of procedural rules and the doctrine of hierarchy of courts.
- Whether the Revised United Nations Standard Minimum Rules for the Treatment of Prisoners (Nelson Mandela Rules) are enforceable and judicially binding in Philippine courts.
- Whether petitioners may be granted provisional liberty on bail or recognizance on the basis of equity jurisdiction and humanitarian considerations without prior hearings in trial courts.
- Whether the Supreme Court has power to determine and modify police power measures chosen by the political branches of government during an emergency such as COVID-19, including policymaking functions like jail decongestion.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)