Title
People vs. Reyes
Case
G.R. No. 101127-31
Decision Date
Aug 7, 1992
Accused convicted of estafa punishable by reclusion perpetua denied bail pending appeal; surrender ordered, affirming non-bailability under Constitution.

Case Digest (G.R. No. 205741)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • Parties Involved
      • Plaintiff-Appellee: People of the Philippines.
      • Accused-Appellant: Cresencia C. Reyes.
    • Nature of the Charges
      • Charged in the Regional Trial Court of Manila, Branch 37, in three separate cases for violations of Batas Pambansa Blg. 22.
      • Charged in two indictments for estafa, specifically under paragraph 2(d) of Article 315 of the Revised Penal Code.
    • Details of Convictions and Sentences
      • In the cases for violations of Batas Pambansa Blg. 22:
        • Appellant was convicted and sentenced to a total penalty of two years of imprisonment and a fine amounting to P96,290.00.
      • In the estafa indictments:
        • Criminal Case No. 86-51209: Convicted and sentenced to twenty-two years of reclusion perpetua with accessory penalties; ordered to indemnify a complaining witness in the sum of P80,540.00, plus cost orders.
        • Criminal Case No. 86-51210: Convicted and sentenced to an indeterminate penalty ranging from six years and one day of prision mayor (minimum) to fourteen years, eight months and one day of reclusion temporal (maximum); accessory penalties including indemnification of P15,750.00 and payment of costs.
  • Procedural History and Pretrial Developments
    • Trial Court Proceedings
      • The cases were jointly tried and decided by Judge Angelina S. Gutierrez on March 12, 1991.
    • Appellate Review
      • The cases were subsequently elevated to the Court of Appeals, which forwarded them to the Supreme Court due to the involvement of the penalty of reclusion perpetua.
    • Provision of Bail
      • At the time of appellate review, Cresencia C. Reyes was under provisional liberty on bail.
      • The bail was secured through a corporate surety bond posted by Oriental Assurance Corporation amounting to P86,000.00; the bond being provided pursuant to the trial court’s May 16, 1991 order.
  • Legal Context and Precedents
    • Constitutional and Statutory Framework
      • The issue was raised in the context of the constitutional prohibition on the imposition of the death penalty and related amendments in the 1987 Constitution regarding bail.
      • Presidential Decree No. 818 (effective October 22, 1975) amended Article 315 of the Revised Penal Code, creating a distinct penalty for estafa by means of deceit (bouncing checks) that falls under reclusion perpetua.
    • Relevant Guiding Jurisprudence
      • Earlier resolution in People vs. Ricardo C. Cortez provided guidelines on the effectivity of bail in criminal cases.
      • The ruling emphasized that if the trial court convicts an accused of an offense punishable by reclusion perpetua, the accused should not remain free on bail pending appeal when evidence of guilt is strong.
  • Explanation of Penal Provisions and Legislative Changes
    • Distinction Between Reclusion Temporal and Reclusion Perpetua
      • Reclusion temporal is specifically defined in the Revised Penal Code with a maximum duration of twenty years.
      • Reclusion perpetua has no such prescribed minimum or maximum; however, by implication and legislative practice, any penalty exceeding twenty years is considered within the ambit of reclusion perpetua.
    • Legislative Intent and Rationale
      • The amendment via Presidential Decree No. 818 was aimed at addressing the surge in estafa cases involving bouncing checks, which threatened the country's commercial confidence and banking systems.
      • The decree was also reflective of the legislative view that certain crimes, because of their gravity (such as financial fraud affecting numerous victims), warrant harsher penalties and stricter conditions regarding bail.
  • Court Orders and Final Disposition
    • Order Issued by the Supreme Court
      • The Court resolved that the bondsman, Oriental Assurance Corporation, must surrender accused-appellant Cresencia C. Reyes to the appropriate Regional Trial Court within ten (10) days from notice.
      • Upon surrender, the Regional Trial Court is directed to immediately order the transmittal of the accused-appellant to the Bureau of Corrections through the Philippine National Police.
    • Purpose and Implications of the Order
      • This measure ensures that the accused is confined pending resolution of her appeal, in line with the constitutional and statutory prohibition on bail for offenses punishable by reclusion perpetua when evidence of guilt is strong.

Issues:

  • Whether an accused-appellant convicted of estafa (a crime punishable by reclusion perpetua) may be allowed to remain on bail during the pendency of the appeal.
    • The central inquiry focuses on the application of bail rules in cases where the sentence involves reclusion perpetua, particularly under the amendment introduced by Presidential Decree No. 818.
    • Whether the general rules laid down in People vs. Ricardo C. Cortez regarding bail remain operable under the current legal framework, especially when dealing with cases of substantial financial fraud.
  • The interpretation and application of constitutional and statutory provisions regarding the non-bailability of offenses punishable by reclusion perpetua.
    • The issue also encompasses the judicial interpretation of the scales of penalties in the Revised Penal Code, notably the demarcation between reclusion temporal and reclusion perpetua.
    • Whether the legislative and judicial policy justifications behind these penal provisions warrant the denial of bail in such cases even if the offense is generally regarded as a crime against property rather than a crime against persons.
  • The role of judicial discretion vis-à-vis legislative intent in determining the eligibility for bail.
    • Whether it is within the judicial province to modify or interpret the rules on bailability in light of evolving statutory amendments and constitutional mandates.
    • How the court balances the rights of the accused with the broader public interest considerations, particularly in cases involving large-scale financial fraud and potential threats to economic stability.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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