G.R. No. L-58805 August 21, 1982
ROMULO BOLAÑOS, CONRADO BELLEN, ALEJANDRO COMETEL and POMPEO DAJERO, petitioners, vs. JUDGE RAFAEL DELA CRUZ, Branch III, Court of First Instance of Camarines Sur and PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Petitioners Romulo Bolaños, Conrado Bellen, Alejandro Cometel, and Pompeo Dajero, along with July Espino, were charged with murder for the death of Romeo Belano. They filed a petition for bail, but its resolution was deferred. While their co-accused Espino was allowed to post bail in 1978, the petitioners’ subsequent petitions for bail were denied by respondent Judge Rafael dela Cruz. The judge found that the prosecution’s evidence strongly indicated their probable guilt for the capital offense.
The prosecution rested its case in 1980, having formally offered evidence that included the petitioners’ alleged extra-judicial confessions (Exhibits E, F, G, and H). These exhibits were admitted over the petitioners’ objections that the confessions were illegally obtained due to lack of substantial compliance with constitutional warning and waiver requirements and were the fruits of arbitrary detention. The petitioners’ motion for reconsideration of the order admitting these confessions was denied. A further reiteration of their petition for bail was also denied, prompting this special civil action.
ISSUE
Whether the respondent judge committed grave abuse of discretion in denying the petitioners’ application for bail and in admitting their extra-judicial confessions into evidence.
RULING
The Supreme Court denied the petition. On the issue of bail, the Court held that under the Constitution, the right to bail before conviction is not available to those charged with a capital offense when evidence of guilt is strong. The determination of whether the evidence of guilt is strong is a task primarily entrusted to the trial court, which had evaluated the prosecution’s evidence, including the contested confessions, and made an affirmative finding. In the absence of a clear showing of manifest abuse of discretion, the Supreme Court will not substitute its judgment for that of the trial court on this factual assessment.
Regarding the admissibility of the extra-judicial confessions, the Court ruled that the petitioners’ contention—that the confessions were obtained in violation of their constitutional rights—is a matter of defense that is best presented and proven during the trial when it is their turn to present evidence. At the stage of the prosecution’s evidence, these confessions must be presumed voluntary and regular until the contrary is duly proved. The proper forum for challenging their voluntariness and admissibility is the trial court itself, not the Supreme Court in a special civil action. The petition was therefore denied for lack of merit.