Facts:
On October 7, 1946, in
G.R. No. L-608,
Procopio Beltran sought a writ of certiorari to annul an order issued by the Fifth Division of the
People’s Court cancelling his bail for provisional liberty and ordering his arrest. Beltran was a
political detainee. On September 15, 1945, the
Solicitor General granted him bail in the amount of
P20,000 pursuant to the authority vested by
Executive Order No. 65. On February 5, 1946, the Office of Special Prosecutors filed an
indictment on twelve counts charging Beltran with
treason. At the same time, the Office of Special Prosecutors filed in the People’s Court a
petition for cancellation of bail, alleging that the evidence of guilt in its possession was strong. The petition was heard on March 2 and 11, 1946 before
Jose P. Veluz, one of the Judges of the Fifth Division. During the hearing, the Special Prosecutor delivered what he described as a limited “recital” or summary of portions of evidence taken from the affidavits of witnesses. No other evidence was presented. Beltran’s counsel objected to the competency and sufficiency of the recital and invoked Beltran’s right to
cross-examine the witnesses and to present evidence in rebuttal. The presiding judge
overruled the objection on the ground that the Special Prosecutor declined to reveal his evidence and indicated that he would present the witnesses only at trial. Beltran then presented two defense witnesses,
Dalmacio Maniquis and
Major Fernando Perello, whose testimony was that Beltran had knowledge of the guerrilla activities of the witnesses and had helped them, but neither witness had knowledge of the treason charges. On March 14, 1946, the Fifth Division ordered the cancellation of Beltran’s bail and directed his arrest, reasoning that the evidence supporting the acts charged was strong “according to the recital made on the record by the Special Prosecutor” and was not rebutted or strengthened by the defense testimony. Beltran moved for reconsideration, but the People’s Court denied the motion on April 13, 1946. Beltran then elevated the matter to the Supreme Court via certiorari, arguing that Judge Veluz, sitting alone, had no authority to hear the bail cancellation petition and that the People’s Court gravely abused its discretion in cancelling bail without competent and strong evidence of guilt being shown at the hearing.
Issues:
Did the People’s Court commit grave abuse of discretion, and lack authority under the
People’s Court Act, when it cancelled Beltran’s bail based on a recital of evidence presented without competent proof and without the required quorum for the sessions in division?
Ruling:
Ratio:
Doctrine: