Case Summary (G.R. No. 129670)
Key Dates
• April 3, 1997 – Warrantless arrest of petitioner via police entrapment
• April 7, 1997 – First information filed (Crim. Case No. Q-97-70550)
• April 29, 1997 – Nine additional informations filed (Crim. Case Nos. Q-97-70866 to Q-97-70874)
• May 16, 1997 – Trial court’s omnibus order on probable cause and bail
• May 23, 1997 – Trial court denies motions to quash and reduce bail; arraigns petitioner
• June 30, 1997 – Court of Appeals decision partially annulling bail conditions
• February 1, 2000 – Supreme Court decision
Applicable Law
• 1987 Philippine Constitution, Art. III, Sec. 14(2) (right to bail; trial in absentia)
• R.A. No. 7610, Sec. 5(b) (sexual abuse of children)
• Rules of Criminal Procedure, Rules 114–116 (conditions and timing of bail; arraignment)
Factual Background
Lorelie San Miguel (16), Mary Ann Tardesilla, Jennifer Catarman, and Annalyn Talingting (minors) separately accused petitioner of engaging in paid sexual intercourse. Following complaints by Lorelie’s parents, police staged an entrapment on April 3, 1997 at the Metropolitan Hotel, where they arrested Lavides with Lorelie clad only in minimal attire.
Procedural History
– April 7, 1997: Information for child abuse filed.
– April 29, 1997: Nine more informations filed alleging multiple acts of exploitation.
– May 16, 1997: RTC finds probable cause, orders detention on the first case, but grants bail at ₱80,000 per case (total ₱800,000) subject to four conditions: mandatory presence at all hearings; automatic forfeiture and in absentia trial if absent; hold-departure order; and approval of bail only after arraignment.
– May 23, 1997: RTC denies motions to quash, refuses to reduce bail, arraigns Lavides (he pleads not guilty) and releases him upon posting bail.
– June 2, 1997: Lavides petitions the Court of Appeals for certiorari.
– June 30, 1997: Court of Appeals invalidates the first two bail conditions (mandatory presence and automatic forfeiture) as contrary to Art. III, Sec. 14(2), but maintains the remainder, including the arraignment prerequisite, holding that issue moot since petitioner had already been arraigned and released.
– Supreme Court review follows.
Issues Presented
- Validity of the RTC condition making bail approval contingent on arraignment.
- Validity of petitioner’s arraignment under that condition.
- Proper remedy for denial of motion to quash — certiorari or trial with eventual appeal.
- Whether multiple informations are required for multiple acts of sexual abuse under R.A. No. 7610.
Analysis
- Bail Versus Arraignment Prerequisite
The RTC’s condition requiring arraignment before bail violates the accused’s right to bail and to challenge an information via motion to quash. Under Rules 114–116, bail should ordinarily be granted before arraignment to permit proper judicial determination of probable cause. Conditioning bail on arraignment coerces the accused to forego motions to quash or remain in detention, undermining due process and the presumption of innocence. - Validity of Arraignment
Even if the arraignment prerequisite is void, arraignment itself was not invalid. Arraignment is mandatory under Rule 116 and Art. III, Sec. 14(2) authorizes trial in absentia only after proper arraignment. Thus, subsequent proceedings, including arraignment and plea, remain valid. - Remedy for Denial of Motion to Quash
The general rule precludes certiorari from a denial of motion to quash; the accused must proceed to trial and raise the issue on appeal. However, in exceptional cases where the denial presents a novel or controlling legal question and appea
Case Syllabus (G.R. No. 129670)
Facts of the Case
- On April 3, 1997, petitioner Manolet O. Lavides was arrested without warrant under R.A. No. 7610 for alleged child abuse following a police entrapment operation.
- Complainant Lorelie San Miguel, then 16, was reported by her parents to have arranged an assignation with petitioner at Room 308 of the Metropolitan Hotel in Quezon City.
- Police entered the room at about 8:20 p.m. and found Lorelie wearing only a T-shirt and underwear; petitioner was placed under arrest.
- A sworn statement by Lorelie and affidavits of the arresting officers supported an inquest that led to an information filed on April 7, 1997 (Criminal Case No. Q-97-70550).
Subsequent Informations and Consolidation
- On April 29, 1997, nine additional informations (Criminal Case Nos. Q-97-70866 to Q-97-70874) were filed against petitioner by Lorelie and three other minors—Mary Ann Tardesilla, Jennifer Catarman, and Annalyn Talingting—alleging sexual intercourse in exchange for money.
- Two more informations later were filed, bringing the total to twelve consolidated cases against petitioner under Article III, Section 5(b) of R.A. No. 7610.
Trial Court Proceedings and Bail Orders
- April 10, 1997: Petitioner filed an Omnibus Motion for judicial determination of probable cause, release from unlawful detention, and bail as a matter of right.
- May 16, 1997: The RTC, Branch 107, Quezon City, ruled:
- Probable cause exists in Criminal Case No. Q-97-70550; petitioner remains under detention.
- Petitioner entitled to bail of ₱80,000 per case (total ₱800,000) subject to four conditions:
• No waiver of appearance during trial (must attend all hearings).
• Automatic forfeiture of bail and issuance of arrest warrants if absent.
• Hold-departure order dated April 10, 1997 remains in effect.
• Approval of bail bonds only after arraignment. - Arraignment set for May 23, 1997 at 8:30 a.m.
- May 20–22, 1997: Petitioner moved to quash nine of the informations, s