G.R. No. 252117 . July 28, 2020
IN THE MATTER OF THE URGENT PETITION FOR THE RELEASE OF PRISONERS ON HUMANITARIAN GROUNDS IN THE MIDST OF THE COVID-19 PANDEMIC, DIONISIO S. ALMONTE, ET AL., PETITIONERS, v. PEOPLE OF THE PHILIPPINES, EDUARDO AÑO, ET AL., RESPONDENTS.

FACTS

The petitioners, who are individuals charged with crimes punishable by reclusion perpetua or life imprisonment and who identify as political prisoners, filed an urgent petition directly with the Supreme Court. They sought their provisional release on bail or recognizance on humanitarian grounds, citing their health conditions and the severe overcrowding and subhuman conditions in detention facilities, which they argued made them highly vulnerable to contracting COVID-19. They invoked the Court’s equity jurisdiction, referencing the case of Enrile v. Sandiganbayan.

ISSUE

Whether the Supreme Court can grant the petitioners’ prayer for temporary release on bail or recognizance on humanitarian grounds in the absence of a proper bail hearing to determine the strength of the evidence of guilt.

RULING

The Supreme Court, through the separate opinion of Justice Caguioa, concurred with the Court’s decision to refer the petition to the concerned trial courts for the conduct of bail hearings and other appropriate proceedings. The opinion held that the Court cannot grant the petitioners’ prayer for temporary release in the absence of a proper bail hearing. For persons charged with a capital offense or an offense punishable by reclusion perpetua or life imprisonment, bail is a matter of judicial discretion, and the grant or denial hinges solely on whether the evidence of guilt is strong. This determination requires a summary hearing where the prosecution presents its evidence and the defense can cross-examine and rebut—a function the Supreme Court cannot perform as it is not a trier of facts. This discretion is primarily lodged with the trial court. While the opinion expressed empathy for the petitioners’ plight and the long-standing, dire conditions of detention facilities, it emphasized that the constitutional and statutory rules on bail must be followed. The opinion also highlighted various administrative measures the Court had already swiftly undertaken to address the risks of COVID-19 in jails, such as circulars on reduced bail and recognizance for indigent persons deprived of liberty and the pilot testing of videoconferencing for hearings.