Case Summary (G.R. No. 99289-90)
Petitioner, Respondent, Key Dates, and Applicable Law
Petitioner: Miriam Defensor Santiago
Respondents: Conrado M. Vasquez, Gualberto J. de la Llana, Sandiganbayan, RTC-Manila
Key Dates:
• May 9–13, 1991 – Information filed; arrest warrant issued with ₱15,000 bail.
• May 14–15, 1991 – Petitioner’s ex parte motion to post cash bail without personal appearance; bond posted.
• May 21, 1991 – Sandiganbayan resets arraignment to May 27; sets aside June 5 appearance order.
• May 24, 1991 – Petitioner secures TRO from Supreme Court enjoining criminal proceedings.
• Jan. 18, 1992 – Supreme Court dismisses petition and lifts TRO; reconsideration denied Sept. 10, 1992.
• July 6, 1992 – Sandiganbayan issues hold-departure order based on petitioner’s announced plans to study abroad.
Applicable Law: 1987 Constitution (Art. III, Sec. 6); Rules of Court (Rule 114 on bail; Rule 135 on inherent powers); jurisprudence on bail jurisdiction, injunction, and travel restrictions (e.g., Feliciano v. Pasicolan; Manotoc, Jr. v. CA; Silverio v. CA).
Background and Procedural History
Petitioner was charged with violating Section 3(e) of RA 3019. After an arrest warrant and bail set at ₱15,000, she filed an ex parte motion to post cash bail and dispense with personal appearance due to injuries. The Sandiganbayan granted the motion, received the bond, and set her physical appearance by June 5. Subsequent pleadings led to an advanced arraignment date, a motion to cancel the cash bond, and a petition for certiorari in the Supreme Court, which granted a TRO on May 24, 1991. The High Court dismissed the petition and lifted the TRO on Jan. 18, 1992. While petitioner’s motion for reconsideration was pending, the Sandiganbayan issued a hold-departure order on July 6, 1992, prompted by media reports of her planned foreign travel.
I. Jurisdiction Over Person and Validity of Bail
– A trial court gains jurisdiction upon issuance of an arrest warrant coupled with the accused’s voluntary submission or arrest.
– Voluntary submission includes filing of motions and posting bail.
– Petitioner’s ex parte motion expressly sought to place her under Sandiganbayan jurisdiction and to post bail; the court accepted the ₱15,000 cash bond.
– Her subsequent motion to cancel the cash bond confirmed her acquiescence to the bond’s validity.
– She is estopped from denying jurisdiction or bond validity after invoking both in her own pleadings.
II. Judicial Comity and Lifting of TRO
– Rule 39, Sec. 4 of the Rules of Court: a judgment dissolving an injunction or restraining order is immediately effective unless stayed by the court.
– A motion for reconsideration does not stay the dissolution of an injunction.
– Once the Supreme Court dismissed the certiorari petition and lifted the TRO on Jan. 18, 1992 (reconsideration later denied), the Sandiganbayan was free to proceed.
– Pendency of a special civil action for certiorari in the Supreme Court does not divest a lower court of jurisdiction absent an injunctive writ.
III. Due Process, Right to Travel, and Freedom of Speech
– Courts possess inherent powers to pre
Case Syllabus (G.R. No. 99289-90)
Background and Facts
- An information for violation of Section 3(e), R.A. No. 3019 (Anti-Graft and Corrupt Practices Act) was filed on May 13, 1991 against petitioner before the Sandiganbayan (Crim. Case No. 16698).
- On May 14, 1991, an arrest warrant was issued with bail fixed at ₱15,000.
- Petitioner, injured in a vehicular accident, filed an ex parte motion to post cash bail and to dispense with her personal appearance until recovery.
- The Sandiganbayan granted provisional liberty on cash bond, deferring her physical appearance until June 5, 1991 at the latest.
Procedural Chronology
- May 15, 1991: Petitioner posted ₱15,000 cash bond.
- May 20, 1991: Ombudsman manifested that petitioner had appeared at his office, accompanied by counsel and a physician.
- May 21, 1991: Sandiganbayan set arraignment for May 27, 1991 and vacated its earlier June 5 appearance order.
- May 22, 1991: Petitioner moved to cancel cash bond and seek recognizance instead.
- May 24, 1991: Petitioner filed a certiorari and prohibition petition with this Court and secured a temporary restraining order (TRO) against the Sandiganbayan and RTC Manila.
- May 27, 1991: Sandiganbayan deferred arraignment and motion on bond pending Supreme Court advice.
- Jan. 18, 1992: This Court dismissed the certiorari petition and lifted the TRO; motion for reconsideration denied on Sept. 10, 1992.
- July 6, 1992: Sandiganbayan issued a hold departure order (HDO) against petitioner pending arraignment and bail.
Petitioner’s Contentions Against the HDO
- Sandiganbayan acted without or in excess of jurisdiction, having not acquired personal jurisdiction over petitioner.
- Issuance of HDO disregarded judicial comity and a pending motion for reconsideration before this Court.
- HDO violated her rights to due process, to travel, and to free speech.
- HDO was issued