G.R. No. 135385 - Cruz vs. Secretary of Environment and Natural Resources

Petitioner Francisco Yap, Jr. was convicted by the Regional Trial Court (RTC) of Pasig City for estafa involving misappropriation amounting to ₱5,500,000.00.
The RTC sentenced him to prision correccional (4 years, 2 months) as minimum to prision mayor (8 years) as maximum, plus one year for each ₱10,000.00 in excess of ₱22,000.00, capped at 20 years.

Petitioner’s motion for provisional liberty under his existing cash bond was denied by the trial court on February 17, 1999.
On appeal to the Court of Appeals (CA), petitioner filed a “Motion to Fix Bail for Provisional Liberty Pending Appeal” under Section 5, Rule 114 of the 1997 Rules of Court.
The Solicitor General recommended bail at ₱5,500,000.00 with conditions: mayoral certification of residence, hold-departure order, passport surrender, and forfeiture clause for non‐compliance.

On October 6, 1999, the CA granted bail at ₱5,500,000.00 subject to the conditions proposed by the Solicitor General.
Petitioner’s motion for reconsideration to reduce bail was denied on November 25, 1999.
Petitioner filed a petition before the Supreme Court, invoking the right against excessive bail and liberty of abode and travel.

Whether fixing bail at ₱5,500,000.00 constitutes an excessive, prohibitory amount effectively denying petitioner’s right to bail.
Whether the CA erred in using petitioner’s civil liability as the basis for determining bail.

Whether the requirement of a mayoral certification of residence and prior notice of transfer unduly restricts petitioner’s constitutional liberty of abode and travel.