G.R. No. 55397 - Tai Tong Chuache and Co. vs. Insurance Commission

On January 19, 1998, Assistant City Prosecutor Leona Castor Castillo of Batangas filed an information with the Regional Trial Court (RTC), Batangas City, charging:

The charging was for the murder of Numeriano Comia, Barangay Chairman, Batangas City.
The case was assigned to respondent Judge Conrado R. Antona.

On January 27, 1998, the trial court issued arrest warrants for all the accused.
On March 10, 1998, an urgent motion by the accused led the court to suspend the efficacy of the arrest warrants pending further orders.
The prosecution filed a motion for reconsideration on March 23, 1998, which the trial court denied on March 31, 1998.
On December 3, 1998, the prosecution filed another motion to lift the suspension.
On December 4, 1998, the trial court granted this motion and issued arrest warrants anew:

On December 15, 1998, while still at large, accused Dante Fajardo and Filipina Fajardo Arce filed an urgent petition for bail.

Accompanied by a supplemental motion for the reduction of bail for accused Pio Arce.

On December 16, 1998, the trial court did not act on the petition since the accused were still at large.
On January 4, 1999, the accused motioned for the resetting of the hearing for the urgent bail petition.

On the same day, the trial court set the hearing on the condition that the accused voluntarily surrender to its jurisdiction as evidenced by their letter dated December 29, 1998.

Instead of the Batangas City Jail, the custody of the accused would be with the PNP Criminal Detection Group at Camp Crame, Quezon City.

To reconsider the court’s order on the custody of the accused.
To declare the bail hearing proceedings null and void.
To request respondent Judge Antona to inhibit himself from the bail proceedings.

On February 1, 1999, the trial court denied the prosecution’s omnibus motion for lack of merit.
On February 15, 1999, the trial court granted the accused’ petition for bail, fixing their bail at P200,000.00 each.
On February 25, 1999, respondent Judge Antona inhibited himself from further involvement in the criminal case.
Thereafter, the petitioner sought judicial relief through a special civil action of certiorari challenging the bail order.

Whether the trial court committed grave abuse of discretion in granting bail to the accused.
Whether the court’s procedures during the bail hearing violated due process.

If the trial court failed to provide the prosecution a reasonable opportunity to present evidence to demonstrate that the evidence of guilt was strong.
Whether the rapid progression of the bail hearing, with preferential treatment for the defense, resulted in a denial of the prosecution’s right to be heard.

Whether permitting bail without a full hearing jeopardizes the State’s duty to protect the public against dangerous elements.