G.R. No. 201883 - Spouses Domingo vs. Spouses Manzano

On October 2, 1986, the Regional Trial Court of Manila, Branch XII, filed an Information charging Rodolfo C. Salas, alias “Commander Bilog,” and co‐accused with rebellion (Art. 134 RPC, in relation to Art. 135). An Amended Information was filed on October 24, 1986.
Salas was arrested on September 29, 1986, at the Philippine General Hospital while in military detention; he had earlier escaped and a ₱250,000 reward was offered for his capture.

On October 3, 1986, a petition for habeas corpus was filed before the Supreme Court, challenging the legality of Salas’s detention and that of co‐accused Josefina Cruz and Jose Concepcion.
On October 16, 1986, the Court dismissed the petition by stipulation: Salas would remain in legal custody and face trial; Cruz and Concepcion would be released on their personal recognizance and submit to the trial court’s jurisdiction.

Salas filed a Motion to Quash on November 7, 1986, alleging lack of jurisdiction and that the facts did not constitute rebellion; this was denied on March 6, 1987.
On May 9, 1987, Salas petitioned for bail. The prosecution opposed (May 27, 1987), arguing rebellion had become a capital offense under PD 1996, 942, and 1834 (penalty reclusion perpetua to death).

By Executive Order 187 (June 5, 1987), the penalty for rebellion was reverted to prision mayor and fine – a bailable offense.
On July 7, 1987, the trial court granted bail at ₱30,000, with a bi‐monthly reporting condition.
The prosecution moved for reconsideration (July 16, 1987; supplemental July 17), seeking higher bail or denial allowing presentation of evidence.
On July 30, 1987, bail was increased to ₱50,000; the court denied the prosecution’s request to introduce evidence for denying bail.

The People filed a petition for certiorari and prohibition in August 1987, contending the trial judge committed grave abuse by granting bail and refusing a hearing on evidence.
A Temporary Restraining Order (Aug. 11, 1987) enjoined enforcement of the July 30 bail order.

May the State deny bail in a bailable offense when public safety or national security is at risk?
Can a person charged with a bailable offense waive the constitutional right to bail?
Did the trial court err by fixing and increasing the bail amount without hearing the prosecution’s evidence under Rule 114, Sec. 10?
Did the trial court commit grave abuse of discretion in granting bail to Salas given his status and flight risk?