Case Summary (G.R. No. 14508)
Summary of Proceedings
Que Ping was convicted of homicide and subsequently filed for appeal with the Supreme Court of the Philippines. To secure his release while the appeal was pending, he executed a bail bond in the amount of P10,000, with the sureties Marquez and Dagala. Following the appeal process and the return of the case records for the court's judgment reading, the court ordered the sureties to produce Que Ping in court. Upon his failure to appear, the court initiated proceedings to forfeit the bond.
Death of the Accused
Subsequently, the sureties claimed that Que Ping had died on April 7, 1917, in San Pablo, Laguna, and therefore sought to be relieved from their obligation under the bond. They presented two exhibits: a death certificate from the municipal secretary of San Pablo and a certificate of death from the president of the municipal board of health. Both documents indicated that Que Ping had died of gastritis on the stated date; however, the court questioned their sufficiency as proof of death.
Evidence Evaluation
The court assessed the evidence presented by the sureties regarding Que Ping's death. The evidentiary value of the documents was acknowledged as prima facie evidence, but not conclusive. The municipal secretary, who transcribed the death record, admitted he had not seen Que Ping’s body. Similarly, the clerical issuer of the death certificate and the sanitary inspector both provided testimonies that lacked direct observation of the deceased. A cemetery porter testified that no burial occurred for Que Ping on the alleged date. The person who allegedly secured the burial certificate was also not called as a witness.
Court's Decision on Bail Forfeiture
The trial court concluded that the death was not satisfactorily established based on the circumstantial and hearsay evidence provided. As a result, the court ruled against the sureties and ordered the forfeiture of the bail since the sureties failed to present adequate proof of Que Ping's death, as it did not absolve them of liability under the bond.
Legal Principles Involved
The pertinent legal principles regarding bail bond obligations are outlined in Philippine statutory law, specifically the Code of Criminal Procedure. According to Section 76, the failure of the defendant to appear without sufficient cause permits the court to forfeit the bail. The court possesses d
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Case Background
- The case involves an appeal by the sureties on the bail bond of Que Ping, a Chinese national charged with homicide in the Court of First Instance of Manila.
- Que Ping was convicted and subsequently appealed the decision to the Supreme Court.
- To secure his release during the appeal, a bail bond amounting to P10,000 was filed, with Bernardo Marquez and Bernardo Dagala serving as sureties.
- The Supreme Court affirmed the trial court's judgment, except for the term of imprisonment.
Proceedings in Lower Court
- Following the Supreme Court's decision, the records were returned for the court to read the decision to Que Ping.
- The Court of First Instance ordered the sureties to produce Que Ping by March 5, 1917, warning that failure to do so would result in forfeiture of the bail.
- When Que Ping did not appear, the court issued a second order requiring the sureties to show cause within thirty days why the bail should not be forfeited.
- The sureties requested an extension which was granted, allowing them sixty days to respond.
Motion for Relief from Obligation
- On April 23, 1917, within the extended period, the sureties filed a motion claiming that Que Ping had died in San Pablo, Laguna.
- The city fiscal objected, leading to a trial to determine the validity of the sureties' claim regarding Que Ping's death.
Court's Findings on Evidence
- Th