G.R. No. 140229 - People vs. Balmoja

Joselito V. Narciso was charged with parricide for the death of his wife, Corazon Sta. Romana-Narciso.
The information was filed on November 13, 1991, before the Regional Trial Court (RTC) of Quezon City, Branch 101, docketed as Criminal Case No. Q-91-24179.
Narciso sought a review of the prosecutor’s resolution before the Department of Justice (DOJ), which was denied twice.
Subsequently, he filed an "Omnibus Motion for Reinvestigation and to Lift the Warrant of Arrest" on February 6, 1992, which resulted in a reinvestigation and recommendation for arraignment and trial.

On August 3, 1992, Narciso filed an "Urgent Ex-Parte (Ex Abundanti Cautela) to Allow Accused Joselito V. Narciso to Post Bail."
The Public Prosecutor did not object, and the Executive Judge granted the motion, allowing bail to be posted at P150,000.00.
No hearing was conducted prior to the grant of bail; the order was issued shortly after the motion was filed.

On August 14, 1992, Flor Marie Sta. Romana-Cruz, sister of the deceased and private complainant, filed an "Urgent Motion to Lift Order Allowing Accused To Post Bail."
Narciso moved to expunge the notice of appearance of the private prosecutor and the motion to lift the bail order.
Arraignment was conducted on September 14, 1992; multiple hearings were scheduled from November 1992 to February 1993.
Private complainant filed opposition to the motion to expunge and sought postponements of the trial pending resolution of the motion to lift the bail order.
The trial court canceled and reset hearings on November 9 and November 23, 1992, citing lack of prosecution witnesses and issues of notification.
No resolution was issued on the motion to lift the bail order.

The private complainant filed a petition for certiorari before the Court of Appeals (CA) to challenge the bail order.
The CA granted the petition and annulled and set aside the order granting bail.
Narciso filed a petition for review on certiorari before the Supreme Court.

Whether the RTC order granting bail to the accused, without conducting any hearing, was valid, particularly in a case involving parricide punishable by reclusion perpetua.

Whether Flor Marie Sta. Romana-Cruz, as a private complainant and sister of the deceased, had the legal personality or standing to challenge the bail order by filing a petition for certiorari.