G.R. No. L-27535 - Lomugdang vs. Javier

On July 13, 1954, Gaudencio Manigbas and eleven others were charged with murder before the Justice of the Peace Court of Rosario, Batangas.
The charge was originally filed by Captain Epigenio Navarro, commanding officer of a constabulary detachment stationed in Alangilang, Batangas.
The complaint was later amended to include an additional accused, Miguel Almario.

Three days after the filing of the original complaint, counsel for the accused filed a motion requesting bail for provisional liberty.
On July 19, 1954, the Justice of the Peace Court issued an order reconsidering its initial denial of bail by granting bail to some accused while continuing to deny bail to others.
Both the defense and the prosecution filed motions for reconsideration—the defense seeking bail for all accused and the prosecution opposing bail on the ground that the court lacked jurisdiction for capital offenses.

On July 21, 1954, the court set aside its July 19, 1954, order and reinstated its original order denying bail to all accused.
The basis for the reversal involved reliance on Supreme Court precedents indicating that a Justice of the Peace had not previously entertained a bail petition in capital cases by holding a hearing on the evidence.

Upon receiving the order reinstating the denial of bail, counsel for the defense filed a petition for mandamus with the Court of First Instance (CFI) of Batangas, which was sitting in Lipa City.
The petition sought to compel the Justice of the Peace Court of Rosario to receive and evaluate evidence to determine if bail was warranted.
After submissions by the provincial commander and the justice of the peace, the CFI on August 24, 1954, granted the petition holding that the Justice of the Peace had the authority to grant bail—even in a case involving a capital offense—and ordered the court to act on the bail application.
An important procedural observation was made: the accused were still at large, and since bail is the security for release only when a person is in custody, the petition for mandamus was considered premature regarding its purpose.

The case raised the controversy as to whether a Justice of the Peace can entertain and act on bail petitions in capital offense cases.
The decision carefully examined constitutional provisions guaranteeing bail, particularly for non-capital cases, as well as specific limitations imposed for capital offenses where evidence of guilt must be shown to be strong.
The Supreme Court’s analysis involved the interpretation of Rule 110 of the Rules of Court and the Judiciary Reorganization Act of 1948 (sections 87 and 91), which were argued as potentially conferring the power to grant bail even in capital offense cases.
A dissenting view stressed that justices of the peace, due to their limited legal training and the non-record nature of their proceedings, were not suitably positioned to evaluate the weight of evidentiary submissions in capital cases.

Whether a Justice of the Peace has the authority to entertain and decide a petition for bail in a case involving a capital offense.

Does the constitutional guarantee of bail extend to cases where a capital offense is charged, and under what conditions?
Can a Justice of the Peace, an officer typically limited to preliminary investigations and non-record proceedings, receive and evaluate the evidentiary submissions necessary to determine whether the evidence for the prosecution is strong enough to warrant a denial of bail?

The procedural propriety of filing a petition for mandamus for bail consideration while the accused are still at large.

Since bail is intended as security for the release of a person in custody, is the petition premature when the accused have not yet been arrested or deprived of liberty?