Facts:

• The case involves bondsmen who surrendered the accused, Armingol Hanasan, to the court and petitioned for his commitment to custody.
• The accused was held on a charge of estafa through falsification of public documents in three criminal complaints filed in the municipal court of the City of Davao.
• Some of the bondsmen became apprehensive that the accused might jump bail following his detention for criminal abduction in another municipality.
• These bondsmen surrendered the accused to the court and requested that he be committed to custody, resulting in the bailment ending and the bondsmen being discharged from their undertaking.
• However, a new surety, Teofilo Flores, signed a separate bail bond to take the place of the bondsmen who had petitioned for the cancellation of their bond.
• The municipal judge ordered the accused's release again, mistakenly believing that the other bondsmen who did not join the petition for cancellation were still bound on their undertaking and became co-sureties of the new bondsman.
• The accused subsequently jumped bail.

Issue:

• (Unlock)

Ruling:

• The bondsmen who did not join the petition to surrender the accused and commit him into custody are not estopped from denying that their bond was still in force.
• The bailment ended when the accused was surrendered and ordered into custody, resulting in all of the bondsmen on the bail bond being discharged from their undertaking.
• Rule 110, Section 16(a) and (b) of the Rules of Court provides for the cancellation of the bail bond and the discharge of the sureties upon surrender of the accused to the court or his re-arrest or order into custody on the same charge or offense.
• Estoppel requires knowledge and assent, which the bondsmen lacked in this case.
• The bondsmen did not hav...(Unlock)

Ratio:

• The court's decision was based on the interpretation of Rule 110, Section 16(a) and (b) of the ...continue reading