Case Summary (G.R. No. 137681)
Facts of the Case
On January 19, 1998, Assistant City Prosecutor Leona Castor Castillo initiated the case by filing an information charging the accused with murder. The case was assigned to Judge Conrado R. Antona. Subsequently, on January 27, 1998, warrants of arrest were issued for the accused. The defense requested suspension of these warrants, which the trial court granted on March 10, 1998, but later denied a prosecution motion for reconsideration on March 31, 1998. The prosecution eventually filed additional motions to lift the suspension, leading to a December 4, 1998 order for the issuance of new arrest warrants for all accused except Pio Arce, who was granted bail at P200,000.
On December 15, 1998, while two of the accused remained at large, they filed an urgent petition for bail. On January 12, 1999, the prosecution filed an omnibus motion contesting the conditions of custody and the proceedings related to the bail petition. Ultimately, on February 15, 1999, the trial court granted bail to the accused. This decision was contested, resulting in the filing of the current petition for certiorari.
The Issue
The core issue presented to the court was whether the trial judge exhibited grave abuse of discretion in granting bail to the accused, particularly in how the bail proceedings were conducted and the opportunities provided to the prosecution to present its case.
The Court’s Ruling
The Court found merit in the petition, highlighting that the Revised Rules of Court stipulate that individuals charged with capital offenses cannot be granted bail when the evidence of guilt is strong. The court emphasized that a rigorous determination must be made, and the prosecution has the burden to demonstrate strong evidence of guilt at a proper hearing, which was deficient in this case.
Despite multiple hearing dates being scheduled, the prosecution faced significant limitations when attempting to present its evidence, as the trial court prioritized a speedy trial for the accused without allowing the prosecution reasonable time for preparation. The court further noted instances where the prosecution was denied the opportunity to counter the evidence put forth by the defense, which violated the due process rights of the State.
In summation, the Court underscored that the exercise of discretion in b
...continue readingCase Syllabus (G.R. No. 137681)
The Case
- This case involves a special civil action of certiorari with a temporary restraining order and a change of venue.
- It challenges the orders issued by respondent Judge Conrado R. Antona, who granted bail to the accused—Dante Fajardo Sr., Paterno de Castro, Filipina Fajardo Arce, and John Doe as principals, along with Pio Arce as accomplice—in a murder case filed in the Regional Trial Court, Batangas City, Branch 04.
The Facts
- On January 19, 1998, Assistant City Prosecutor Leona Castor Castillo filed an information with the Regional Trial Court, charging the accused with the murder of Numeriano Comia, the Barangay Chairman of Batangas City.
- The case was subsequently assigned to Judge Conrado R. Antona’s sala.
- Arrest warrants for the accused were issued on January 27, 1998.
- On March 10, 1998, the trial court temporarily suspended the execution of the arrest warrants until further orders.
- The prosecution filed a motion for reconsideration against the suspension on March 23, 1998, which was denied on March 31, 1998.
- On December 4, 1998, the trial court lifted the suspension, issuing arrest warrants without bail for the accused, except for Pio Arce, whose bail was set at P200,000.00.
- On December 15, 1998, while still at large, accused Dante Fajardo and Filipina Fajardo Arce filed an urgent petition for bail with a supplemental motion for the reduction of bail for Pio Arce, Jr.
- The trial court did not act on the petition on December 16, 1998, due to the accused being