Case Digest (G.R. No. 115407)
Facts:
- Miguel P. Paderanga was the petitioner against the Court of Appeals and the People of the Philippines.
- In 1984, Paderanga, then mayor of Gingoog City, was implicated in the multiple murder of the Bucag family.
- Original information was filed on October 6, 1986, against eight accused; only Felipe Galarion was apprehended and convicted.
- Galarion escaped from prison, while the other accused remained at large.
- In 1988, Felizardo Roxas was charged as a co-accused and implicated Paderanga as the mastermind in a signed affidavit, which he later retracted.
- On January 28, 1990, Paderanga was charged as a co-conspirator in an amended information.
- Paderanga filed a motion for bail on October 28, 1992, while hospitalized due to acute costochondritis.
- The trial court granted bail on November 5, 1992, allowing Paderanga to post P200,000.
- The prosecution filed a motion for reconsideration, which was denied, and subsequently elevated the matter to the Court of Appeals.
- The appellate court annulled the trial court's decision on November 24, 1993, citing grave abuse of discretion.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that Paderanga was constructively in the custody of the law when he filed his application for bail.
- The Court found that the trial court did not violate procedural due process, as the prosecution had waived its right to present evidence against the bail application....(Unlock)
Ratio:
- The Supreme Court emphasized that a person seeking bail must be in the custody of the law, which can be established through actual arrest or voluntary surrender.
- Paderanga's bail application while hospitalized constituted a constructive submission to the court's jurisdiction, effectively placing him in custody.
- The Court referenced previous rulings, including Santiago vs. Vasquez, to support that filing a motion for bail can confer jurisdiction over the accused.
- Regardi...continue reading
Case Digest (G.R. No. 115407)
Facts:
The case involves Miguel P. Paderanga as the petitioner against the Court of Appeals and the People of the Philippines as respondents. The events leading to this case began in 1984 when Paderanga, then the mayor of Gingoog City, was implicated in the multiple murder of the Bucag family. The original information was filed on October 6, 1986, against eight accused, but only one, Felipe Galarion, was apprehended and later convicted. Galarion escaped from prison, and the other accused remained at large. In 1988, Felizardo Roxas was charged as a co-accused and later implicated Paderanga as the mastermind behind the murders in a signed affidavit, which he later retracted.
On January 28, 1990, Paderanga was charged as a co-conspirator in an amended information. Following a series of legal maneuvers, including a Supreme Court ruling that upheld the second amended information against him, Paderanga filed a motion for admission to bail on October 28, 1992, while he was hospitalized due to acute costochondritis. The trial court granted his bail application on November 5, 1992, allowing him to post bail of P200,000. However, the prosecution, represented by Prosecutor Henrick F. Gingoyon, filed a motion for reconsideration, which was denied. Subsequently, the prosecution elevated the matter to the Court of Appeals, which annulled the trial court's decision on November 24, 1993, citing grave abuse of discretion. The appellate court argued that Paderanga was not in the custody of the law when he applied for bail and that the evidence of guilt was s...