Facts:

• The case involves the extradition of Juan Antonio Muñoz, charged with bribery and conspiracy to defraud in Hong Kong.
• The Philippines and Hong Kong had an "Agreement for the Surrender of Accused and Convicted Persons," effective June 20, 1997.
• Hong Kong reverted to China on July 1, 1997.
• Arrest warrants for Muñoz were issued on August 23, 1997, and October 25, 1999.
• The Philippine DOJ received a request for Muñoz's provisional arrest on September 13, 1999.
• Muñoz was arrested by the NBI on September 23, 1999.
• Muñoz contested the arrest, but the Supreme Court upheld its validity on December 18, 2000.
• The Hong Kong Special Administrative Region filed an extradition petition on November 22, 1999.
• Muñoz's initial bail petition was denied by Judge Ricardo Bernardo, Jr., who deemed him a flight risk.
• After Judge Bernardo's inhibition, Judge Felixberto T. Olalia, Jr. granted Muñoz's motion for reconsideration and allowed bail on December 20, 2001.
• The DOJ's motion to vacate this order was denied on April 10, 2002, leading to the instant petition for certiorari.

Issue:

• (Unlock)

Ruling:

1. The Supreme Court ruled that a potential extraditee has the right to apply for bail.
2. The case was remanded to the trial court to determine if Muñoz is entitled to bail based on...(Unlock)

Ratio:

• The Supreme Court recognized that the constitutional right to bail traditionally applies to criminal proceedings.
• International human rights obligations necessitate a broader interpretation of the right to bail.
• The Court cited the Universal Declaration of Human Rights and the International Covenant on Civil and Political Rights, emphasizing liberty and due process.
• Past Philippine ...continue reading