Case Digest (G.R. No. L-62100) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Ricardo L. Manotoc, Jr. v. Court of Appeals, petitioner Ricardo L. Manotoc, Jr., a principal stockholder and president of Trans-Insular Management, Inc., was implicated in six estafa complaints filed by clients of Manotoc Securities, Inc. In early 1980 the Securities and Exchange Commission (SEC) requested that the Commissioner of Immigration, Hon. Edmundo M. Reyes, bar petitioner from departing the Philippines pending its investigation. On February 4, 1980, Immigration Regulation Division was so instructed. The investigating Fiscal thereafter filed informations for estafa (Criminal Cases Nos. 45399 & 45400) before Judge Serafin E. Camilon and (Criminal Cases Nos. 45542–45545) before Judge Ricardo L. Pronove of the Court of First Instance of Rizal, Pasig Branches. Petitioner was admitted to bail totaling ₱105,000.00 with FGU Insurance Corporation as surety. On March 1, 1982, he filed motions for permission to leave the country “relative to his business transactions and opport Case Digest (G.R. No. L-62100) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and corporate involvement
- Petitioner Ricardo L. Manotoc, Jr. is principal stockholder of Trans-Insular Management, Inc., and co-stockholder of Manotoc Securities, Inc., acting as president of the former.
- In response to a market “run” on stock brokerages, petitioner and co-stockholders filed with the Securities and Exchange Commission (SEC) petitions for appointment of management committees for both corporations; SEC granted relief for Manotoc Securities, Inc. (SEC Case No. 001826).
- Criminal complaints, indictment, and bail
- After the acceptance of a suspicious Torrens title by Manotoc Securities, six clients filed criminal complaints for estafa against petitioner and corporate officers.
- Corresponding informations were filed in CFI Rizal: Criminal Cases Nos. 45399–45400 (Judge Camilon) and Nos. 45542–45545 (Judge Pronove). Petitioner was admitted to bail in the aggregate amount of ₱105,000 with FGU Insurance as surety.
- Motions to travel and initial denials
- February 4, 1980: SEC requested Immigration not to clear petitioner for departure; Immigration Regulation Division memorandum issued.
- March 1, 1982: petitioner moved in both trial courts for permission to leave the country for U.S. business; Judges Camilon (Mar. 9) and Pronove (Mar. 26) denied the motions, citing absence of urgency, unspecified duration, and surety risk.
- Procedural history of appeals
- Petitioner sought certiorari and mandamus in the Court of Appeals to annul trial-court orders and SEC/Immigration refusals; CA dismissed petition on Oct. 5, 1982.
- Supreme Court granted review on April 14, 1983. August 15, 1984: petitioner moved for pendente lite travel, attaching U.S. investment invitation and noting dismissal of cases Nos. 45542–45545; CFI Makati amended remaining informations rather than dismiss them.
- September 20, 1984: SC en banc denied leave to travel pendente lite.
Issues:
- Whether a person provisionally released on bail has an unrestricted constitutional right to travel abroad.
- Whether courts or administrative bodies (SEC, Immigration, AVSECOM) may lawfully restrict such travel.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)