G.R. No. 78777 - Caina vs. People

The writ of habeas corpus, a long‐standing remedy against unlawful detention, is enshrined in the Constitution and ensures that any person deprived of liberty may have the legality of their detention reviewed by a court.
The Constitution explicitly provides that the privilege of the writ of habeas corpus shall not be suspended except in cases of invasion, insurrection, or rebellion when public safety so requires (Article III, Section 1, Paragraph 14), with the power to suspend it vesting in the President (Article VII, Section 10, Paragraph 2).

In 1905, Governor General Luke E. Wright issued an executive order suspending the writ of habeas corpus in Batangas and Cavite to address violent criminal bands levying forced contributions and perpetrating attacks.
On October 22, 1950, President Elpidio Quirino issued Proclamation No. 210, suspending the writ for persons suspected of sedition, insurrection, or rebellion in view of overt acts of lawlessness and to maintain public safety, particularly in connection with the apprehension and detention of 100 alleged leaders of lawless elements.

The suspension of the privilege of the writ in the 1950 proclamation was designed to enable law enforcement to detain suspects without interference from judicial review through habeas corpus while investigations were conducted.
Once formal judicial proceedings commenced – with the filing of an information charging the accused with crimes (including rebellion, multiple murder, arson, and robberies) – the detention shifted from an executive investigation to a matter under judicial jurisdiction.

The consolidated cases (G.R. Nos. L-4855, L-4964, and L-5102) involve petitioners challenging whether the President’s suspension of the writ of habeas corpus also suspends the constitutional right to bail for those charged with rebellion or related crimes.
The petitioners argued that by suspending habeas corpus, the Executive effectively deprived accused persons of using one traditional remedy (which includes obtaining bail) to secure their liberty, even after the filing of a judicial information.

After the filing of the information, some accused persons sought bail, while lower court judges, noting the executive suspension of the writ, at times denied bail or ordered provisional release inconsistently.
A controversial order by a trial judge granted bail under circumstances that were later challenged on the ground that it conflicted with the executive’s proclamation and the ambit of the suspension.

Does the suspension of the writ of habeas corpus, as executed by the President pursuant to the Constitution, implicitly or expressly suspend the right to bail for individuals charged with rebellion or insurrection once formal judicial proceedings have begun?

Is there a distinction between detention under executive authority and detention under judicial process regarding the availability of bail?
Can judicial remedies such as mandamus, certiorari, or habeas corpus be employed after the filing of an information to compel the admission of bail?
To what extent does the suspension affect other constitutional rights of the accused, notably the right to a speedy trial and the exercise of due process?