G.R. No. 201247 - Engineering and Construction Corporation of Asia vs. Palle

Petitioners Aniceto and Laureana Sabbun Maguddatu, Atty. Teodoro Rubino, Antonio Sabbun Maguddatu and “John Does” were charged with murder in RTC Makati, Branch 64.
On October 23, 1985, petitioners moved for bail alleging weak prosecution evidence; on December 20, 1985, the trial court granted bail at ₱30,000 each and petitioners posted bail through AFISCO Insurance Corporation.

On January 6, 1987, AFISCO moved to cancel the bail bond for failure to renew it upon its December 20, 1986 expiration; the trial court took no action.
On January 2, 1998, after remaining at large, petitioners were convicted in absentia of homicide and sentenced to 8 years prision mayor (minimum) to 14 years 8 months reclusion temporal (maximum); an arrest order issued February 19, 1998.

On February 27, 1998, petitioners filed a Notice of Appeal with a motion for provisional liberty under their bail bond; the trial court did not resolve the motion and forwarded records to the Court of Appeals (CA).
On January 8, 1999, the CA ordered petitioners to show cause why their appeal should not be dismissed for failure to submit to jurisdiction; petitioners filed a Compliance and Motion on February 8, 1999 but still remained at large.
On June 23, 1999, the CA denied bail, recalled no order of arrest, and warned that failure to surrender within ten days would result in appeal dismissal; on September 8, 1999, the CA dismissed the appeal as abandoned.

Whether petitioners are entitled to bail as a matter of right or only at the court’s discretion under the Constitution and Rule 114.
Whether the trial court or the CA committed grave abuse of discretion in denying bail pending appeal and recalling the arrest order.
Whether petitioners violated the conditions of their bail bond and whether the bond remained effective after its expiration.