Case Summary (G.R. No. 45129)
Key Dates
The decision was rendered on September 24, 1936.
Applicable Law
This case references the Revised Penal Code of the Philippines and General Orders, No. 58, as amended by Act No. 4178. It also implicitly cites constitutional provisions regarding bail, with particular emphasis on the limitations placed on individuals convicted of capital crimes.
Background of the Case
Following the trial court’s judgment sentencing Follantes to reclusion perpetua for murder, he filed a motion seeking the allowance of bail in the amount of P15,000. This motion was prompted by the request for provisional liberty while his appeal was pending.
Legal Framework on Bail
The law categorically states that crimes punishable by death, which includes murder, are non-bailable except under specific circumstances, mainly that there must be a lack of strong evidence against the accused prior to conviction. This principle is established under Article III, Section 1, No. 16 of the Philippine Constitution, which limits the right to bail for those convicted of capital offenses.
In terms of non-capital crimes, the eligibility for bail after conviction hinges on the judicial discretion of the court, particularly if the conviction arises from courts other than those of justices of the peace. Section 64 of General Orders, No. 58 outlines that defendants can avail of bail as a right following a judgment in those less severe cases.
Court's Decision
The court firmly stated its position that Follantes should not be granted bail while awaiting the final resolution of his appeal. The rationale was based on the nature of his conviction for a capital crime, which under existing legal standards, disallowed bail pending appeal.
Conclusion on Petition
The petition for bail was ultimately denied, affirming the legal prin
...continue readingCase Syllabus (G.R. No. 45129)
Case Overview
- This case involves Anacleto Follantes, who was convicted of murder and sentenced to the penalty of reclusion perpetua.
- Following his conviction, Follantes sought to perfect bail amounting to P15,000, which had been authorized for his provisional liberty while he appealed the judgment.
- The bail request was made in the municipality of Jones in the Province of Isabela.
Legal Context
- The crime of murder is classified under Article 248 of the Revised Penal Code, which prescribes penalties ranging from reclusion temporal in its maximum period to death.
- Under Philippine law, individuals convicted of capital crimes, such as murder, are not entitled to bail post-conviction.
- The Constitution of the Philippines allows for bail before conviction only if the evidence of guilt is not strong (Article III, Section 1, No. 16).
- For non-capital crimes, the ri