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

On April 9, 2020, petitioners, who are detainees and prisoners, filed a direct petition before the Supreme Court seeking temporary liberty through bail or personal recognizance on humanitarian grounds due to the COVID-19 pandemic. They described themselves as elderly, sickly, or with medical conditions that make them vulnerable to COVID-19, and are detained in facilities where social distancing and other precautions are impossible. The petition was filed a month after Presidential Proclamation 922 declared a state of public health emergency. Petitioners invoked the Court’s equity powers under Sections 1 and 5(5) of Article VIII of the 1987 Constitution and Rule 3, Section 1 of A.M. No. 10-4-20-SC, bypassing standard procedures for bail or recognizance applications.

ISSUE

The primary issue raised by petitioners is whether they, being elderly, sickly, and with medical conditions, should be released on humanitarian considerations due to COVID-19. The Court, during deliberations, formulated additional issues: (A) whether the petition filed directly before the Supreme Court may be given due course; (B) whether the Nelson Mandela Rules are enforceable in Philippine courts; (C) whether petitioners may be given provisional liberty on the ground of equity; and (D) whether the Court has the power to pass upon the State’s prerogative of selecting appropriate police power measures in times of emergency.

RULING

Justice Zalameda, in his Separate Opinion, voted to DENY the petition. He held that the Supreme Court is not vested with jurisdiction over applications for bail or recognizance, as such jurisdiction lies with the trial courts under Rule 114 of the Revised Rules on Criminal Procedure and Republic Act No. 10389 . Petitioners failed to comply with the procedures for these applications and did not substantiate their right to release. The determination of facts, such as the authenticity of submitted documents, is best left to trial courts. Furthermore, the Court should not interfere with the State’s exercise of police power in addressing the pandemic, as the executive branch has implemented measures within detention facilities to mitigate COVID-19 risks. The opinion also noted that the Nelson Mandela Rules, while persuasive, are not directly enforceable as domestic law without local legislation.