Case Summary (G.R. No. 198701)
Factual Background
Over 300 armed soldiers led by junior AFP officers occupied Oakwood Premier Apartments and demanded high-level resignations. President Arroyo declared a state of rebellion, later lifted. Trillanes surrendered and was charged under Article 134-A, RPC. He remained in the Marine Brig, Fort Bonifacio, from June 2006 onward.
Procedural History
On June 22, 2007, Trillanes filed an Omnibus Motion in RTC Makati seeking permission to: (a) attend all Senate sessions and related functions; (b) establish a detention-based office; (c) meet staff and resource persons; (d) grant media access; (e) admit press interviews in detention; and (f) attend Senate organizational meetings. The RTC denied all requests on July 25, 2007, and again on September 18, 2007, after partial reconsideration. Trillanes then petitioned the Supreme Court for certiorari, prohibition, and mandamus.
Applicable Law on Bail and Political Rights
Under the 1987 Constitution Art. III, Sec. 13, all persons charged with offenses—except those punishable by reclusion perpetua with strong evidence—are entitled to bail. Rule 114 of the Rules of Court denies bail when evidence of guilt is strong for capital or reclusion perpetua offenses “regardless of the stage of the criminal action.” Coup d’état and rape both carry penalties of reclusion perpetua.
Arguments of the Petitioner
Trillanes argued: (1) presumption of innocence entitles him to full civil and political rights; (2) coup d’état is a political, not moral-turpitude, offense; (3) election to the Senate condones any prior misconduct; (4) precedents (e.g., Estrada, Misuari) permitted detention prisoners to attend functions; (5) denial of his motion frustrated the people’s will and representation.
Distinction From Jalosjos
Trillanes sought to distinguish People v. Jalosjos on grounds that Jalosjos was convicted, charged with sex crimes, and a flight risk. The Court held these distinctions immaterial: elected officials in custody cannot claim special privilege to perform legislative duties; presumption of innocence does not override lawful custody restrictions.
Constitution’s Bail Provisions and Rule 114
The Court emphasized that coup d’état is non-bailable when evidence is strong. Trillanes’s prior bail applications had been denied under RTC orders of July 2004 and June 2006. Whether pretrial detainee or convict, the rationale of public self-defense and jail security equally bars full exercise of office functions while detained.
Public Self-Defense and Detention
Citing Maceda and Alejano, the Court noted that detention inherently restricts liberty far beyond mere movement. Legislative work cannot justify creating a “special class” of detainee free to attend sessions, which would undermine correctional objectives and public safety.
Flight Risk and Manila Peninsula Incident
Despite voluntary surrender, Trillanes’s February 2008 escape attempt during a court proceeding and unauthorized trip to the Manila Peninsula Hotel demonstrated real flight risk. Such conduct reinforced denial of expanded privileges and underscored Rule 114’s focus on strong evidence rather than detainee status.
Election as Senator and Condonation Doctrine
The Court rejected the claim that re
...continue readingCase Syllabus (G.R. No. 198701)
Facts of the Case
- On July 27, 2003, over 300 armed soldiers under junior AFP officers occupied Oakwood Premier Apartments, Makati City, demanding the resignation of the President and key officials (“Oakwood Incident”).
- President Gloria Macapagal Arroyo issued Proclamation No. 427 and General Order No. 4 declaring a state of rebellion; the mutineers surrendered that evening.
- Antonio F. Trillanes IV was charged with coup d’état under Article 134-A, Revised Penal Code, in RTC Makati as Criminal Case No. 03-2784 (“People v. Capt. Milo D. Maestrecampo, et al.”).
- Trillanes remained in detention since June 13, 2006, first at ISAFP, then at Marine Brig, Fort Bonifacio.
- He ran for the Senate while in custody, won in May 2007, and his term began June 30, 2007.
Omnibus Motion Filed by Petitioner
- On June 22, 2007, Trillanes filed an “Omnibus Motion for Leave of Court to be Allowed to Attend Senate Sessions and Related Requests” in RTC Makati, Branch 148.
- His original requests:
• Attend all official Senate functions, sessions, hearings, meetings (Mondays–Thursdays, 8 a.m.–7 p.m.) at Pasay City or elsewhere.
• Establish a working area in detention (computer, phone, internet) at Senate expense.
• Receive staff, resource persons, and guests in detention for legislative work.
• Grant media interviews and comment publicly while performing senatorial duties.
• Allow media visits at detention on Tuesdays and Fridays.
• Attend Senate organizational meeting and election of officers on July 23, 2007.
Trial Court Proceedings and Orders
- By Order of July 25, 2007, the trial court denied all requests.
- Trillanes moved for reconsideration, withdrew requests for working area, staff meetings, and Senate organizational meeting.
- RTC denied reconsideration on September 18, 2007.
- Trillanes then filed a petition for certiorari, prohibition, and mandamus before the Supreme Court to set aside both RTC orders and compel respondents to grant access.
Change of Custody and Parties
- Respondents in