G.R. No. 135012 - Esteban vs. Alhambra

Anita Esteban, the petitioner, filed a petition for certiorari challenging court orders issued by Judge Reynaldo A. Alhambra of the RTC, Branch 39, San Jose City.
The orders challenged were dated July 9, 1998, and August 20, 1998, and pertained to four criminal cases (Criminal Cases Nos. SJC-88(95), SJC-27(97), SJC-30(97) and SJC-31(97)).

Gerardo Esteban, the accused and brother-in-law of the petitioner, had a cash bail of ₱20,000.00 posted in each of the four cases by Anita Esteban on his behalf, allowing him provisional liberty.
While out on bail for these cases, Gerardo was charged with an additional crime, leading to his arrest and detention in a separate criminal case.

On June 18, 1998, petitioner's frustration over Gerardo’s repeated offenses led her to file an application for the cancellation of the cash bail bonds.
In her application, she asserted that the cancellation should be effected on the basis that the accused had already been detained by the police, as evidenced by certification from the City Jail Warden.
The petitioner based her claim on Section 22 (formerly Section 19) of Rule 114 of the Revised Rules of Criminal Procedure, which provides for the cancellation of bail upon the surrender of the accused or proof of his death.

The trial court, by an Order dated July 9, 1998, denied the petitioner's request citing that:

The accused was not voluntarily surrendered to the court.
His arrest in a subsequent criminal case did not alter the nature of the cash bail previously deposited.
Cash deposits, even when made by a third person, are treated as the property of the accused, intended for the payment of fines and costs.

The petitioner filed a motion for reconsideration, which was subsequently denied by an Order dated August 20, 1998.

The petitioner contended that the trial court committed grave abuse of discretion or acted with lack/excess of jurisdiction in denying the cancellation of the bail bonds.
She further argued that the matter presented was one of first impression and should be resolved in her favor based on the provisions of Section 22 (formerly Section 19) of Rule 114.

Whether the cancellation of a cash bail bond is permitted under Section 22 (formerly Section 19) of Rule 114 when the accused has been arrested in a subsequent case, rather than being voluntarily surrendered to the trial court.
Whether the trial court’s Orders denying the cancellation of the cash bail bonds amounted to a grave abuse of discretion or lack/excess of jurisdiction.
Whether the nature of a cash bail deposit—as being treated as the property of the accused for the purpose of payment of fines and costs—precludes the possibility of its cancellation by the petitioner.