G.R. No. L-278 - Teehankee vs. Director of Prisons

Petitioner Haydee Herras Teehankee, a political detainee, was arrested by the Counter Intelligence Corps Detachment of the United States Army.
She was charged with “active collaboration with the Japanese” and “previous association with the enemy” under Security Commitment Order No. 286.
Following her transfer to the Commonwealth government under General MacArthur’s proclamation, she remained in custody despite no formal information being filed against her under the People’s Court Act or the applicable penal statutes.

On October 2, 1945, the petitioner filed a petition seeking temporary release under bail.
The People’s Court, through Judge Antonio Quirino’s order of October 9, 1945, after a recommendation by the Office of Special Prosecutors (which suggested a bail bond of 50,000 pesos), denied her application despite indications that her release should be considered.
A motion to reconsider this order was filed but later denied on October 13, 1945.

The petitioner sought relief through a petition for certiorari and mandamus before the Supreme Court, asking that the People’s Court orders be set aside for abuse of discretion and lack of proper hearing.
On December 20, 1945, the Supreme Court issued a judgment setting aside the People’s Court’s orders, and it directed that a proper hearing be held regarding the petitioner’s bail application.
Following this decision, the People’s Court held a hearing on December 27, 1945, where the petitioner renewed her verbal application for bail. Although the Special Prosecutor did not object, the presiding judge questioned him to compel disclosure of the prosecution’s evidence.
Additional hearings occurred on January 15 and January 28, 1946, during which the judge—despite previous instructions—attempted to privately inquire into the prosecutor’s evidence, ultimately denying bail based on alleged “a myriad of points” against the petitioner.
The petitioner then filed a verified petition and later a supplementary petition for certiorari and habeas corpus, insisting that the People’s Court’s private inquiry and repeated non-decision constituted a grave abuse of discretion.

The dispute involved a conflict between section 19 of Commonwealth Act No. 682 (the People’s Court Act) and the constitutional guarantee found in Article III, Section 1, Paragraph 16, which provides that “all persons shall before conviction be bailable…” except in capital cases when evidence of guilt is strong.
Previous Supreme Court decisions—most notably Herras Teehankee vs. Rovira and cases such as Raquiza vs. Bradford—had addressed the proper scope of judicial discretion and the requirement for public or adequately noticed hearings in bail applications.
The issues involved whether a detainee not yet formally charged is entitled to bail as a matter of right and whether the People’s Court properly exercised its discretion in handling the bail application for a detainee charged with a potential capital offense.

Does the constitutional precept “all persons shall before conviction be bailable…” extend to detainees who are not yet formally charged, such as political prisoners?
How should the exception for capital offenses—“except those charged with capital offenses when evidence of guilt is strong”—be interpreted in cases where formal charges have not yet been filed?

Whether the People’s Court’s repeated denials and its refusal to conduct a hearing with proper notice to the petitioner constitute an abuse of judicial discretion.
Whether the method of privately inquiring into the Special Prosecutor’s evidence, against prior Supreme Court instructions, violated the petitioner’s right to a fair and open process.

Whether, in a combined proceeding for certiorari and habeas corpus, the Supreme Court has the inherent authority to directly grant provisional release on bail without remanding the matter to the People’s Court.
Whether granting bail directly in this petition interferes with the appellate review process under the standard rules for certiorari.