Title
Narciso vs. Sta. Romana-Cruz
Case
G.R. No. 134504
Decision Date
Mar 17, 2000
Joselito Narciso charged with parricide; RTC granted bail without hearing. CA annulled bail order; SC upheld, ruling hearing mandatory for capital offenses, sister had standing to challenge.

Case Summary (G.R. No. 30342)

Key Dates

Relevant procedural and adjudicative dates include: information for parricide filed November 13, 1991; motion for reinvestigation and related filings in early 1992; accused’s urgent ex parte motion to post bail and the RTC Order allowing bail on August 3, 1992; arraignment held September 14, 1992; RTC orders of November 9 and November 23, 1992 relating to trial scheduling and subpoenas; Court of Appeals decision of February 26, 1998 and CA resolution of June 29, 1998; Supreme Court decision resolving the present petition on March 17, 2000.

Applicable Law and Constitutional Basis

Because the decision date is 1990 or later, the Court applied the 1987 Constitution. The pertinent constitutional provision is Section 13, Article III (right to bail, except where evidence of guilt is strong in offenses punishable by reclusion perpetua). Procedural rules relied upon include Section 7, Rule 114 of the Rules of Court (no bail for capital/reclusion perpetua/life imprisonment offenses when evidence of guilt is strong) and related sections requiring notice to the prosecutor and a hearing in such cases. Prior jurisprudence interpreting these provisions was extensively cited.

Factual Summary

The prosecutor filed an information for parricide against petitioner on November 13, 1991. Petitioner sought reinvestigation and relief at the Department of Justice, which was denied; reinvestigation by another prosecutor confirmed remand for arraignment and trial. On August 3, 1992 petitioner filed an ex parte urgent motion to allow posting of bail; the public prosecutor registered no objection and the Executive Judge approved a P150,000 cash bond on the same day. The private prosecutor (representing the deceased’s sister) later filed an urgent motion to lift the order allowing bail and, after various pretrial motions and scheduling, sought relief from the Court of Appeals when no resolution had been obtained from the trial court.

Procedural Posture and Relief Sought

The Court of Appeals granted the private respondent’s petition for certiorari and annulled the RTC order granting bail. The CA denied the petitioner’s motion for reconsideration. The petitioner then filed the present petition for review on certiorari under Rule 45 challenging the CA’s annulment of the bail order.

Issues Presented

  1. Whether the RTC order granting bail was valid despite the absence of a hearing and despite the prosecution’s lack of opposition. 2) Whether the private respondent (the deceased’s sister) had legal personality or standing to challenge the RTC order in the Court of Appeals.

Supreme Court’s Disposition

The petition was denied and the Court of Appeals’ decision affirming annulment of the trial court’s bail order was affirmed. Costs were assessed against petitioner.

Rationale on Validity of the Bail Grant

The Court held that when an offense is punishable by reclusion perpetua (as parricide is), the Constitution and Rule 114 require that a hearing, summary or otherwise, be conducted to determine whether the evidence of guilt is strong before bail may be granted. The judge, not the prosecutor, must exercise the judicial discretion to assess whether the prosecution’s evidence shows strong guilt. The absence of a hearing — in this instance the bail order issued within about ten minutes of filing and without receiving or evaluating evidence — constituted grave abuse of discretion and effectively a lack of jurisdiction. Prior cases cited (including Basco v. Rapatalo, Baylon v. Sison, Gimeno v. Arcueno, Concerned Citizens v. Elma and others) establish the mandatory duty to conduct a hearing, to notify or require the prosecutor’s recommendation, to summarize the prosecution’s evidence in the order, and to base the bail disposition on an evaluation at that hearing. The Court emphasized that the prosecution’s non‑objection cannot substitute for the trial judge’s duty to conduct the hearing and weigh the evidence; judicial discretion cannot be ceded to the prosecutor. Because the grant in this case lacked the required hearing and summary of evidence, it was void for grave abuse of discretion and properly annulled by the CA.

Rationale on Private Respondent’s Standing

Petitioner contended that only public prosecutors or the Solicitor General may challenge orders on behalf of the People and that a private prosecutor lacked authority to bring the certiorari petition. The Court recognized the general rule that the Solicitor General represents the State in appellate proceedings but invoked an exception grounded in the ends of substantial justice. Given that the RTC order was void for grave abuse of discretion amounting to lack of jurisdiction, the Court held that a private party directly aggrieved — here

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