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 6, 2020, a group of prisoners filed a petition directly with the Supreme Court. The petitioners, who identified themselves as among the elderly, sick, and pregnant inmate population, alleged that their continued confinement during the COVID-19 pandemic exposed them to a high risk of contracting the disease due to the impossibility of social distancing and self-isolation in congested penal facilities. They invoked the Court’s “equity jurisdiction” and sought “temporary liberty on humanitarian grounds” either on recognizance or on bail. They also asked the Court to order the creation of a “Prisoner Release Committee” to study and implement the release of prisoners to decongest jails, citing practices in other countries. Their arguments included that their confinement constituted cruel and unusual punishment, that the State had a duty under international standards like the UN Nelson Mandela Rules to protect prisoner health, and that existing government measures were insufficient.
The respondents, represented by the Office of the Solicitor General, opposed the petition. They argued that the petitioners were members of the CPP-NPA-NDF who had committed heinous crimes and were exploiting the pandemic. They asserted that the government had adequate medical measures in place within detention facilities. They also contended that the petitioners violated the doctrine of hierarchy of courts, that the determination of bail and medical conditions were factual questions for trial courts, and that the petitioners, charged with capital offenses, could not be released on recognizance.

ISSUE

The main issues, as framed by the Court, were:
1. Whether the petition filed directly before the Supreme Court may be given due course.
2. Whether the Nelson Mandela Rules are enforceable in Philippine courts.
3. Whether petitioners may be given provisional liberty on the ground of equity.
4. Whether the Court has the power to pass upon the State’s prerogative of selecting appropriate police power measures in times of emergency.

RULING

The Supreme Court, sitting En Banc, unanimously decided to treat the petition as the petitioners’ applications for bail or recognizance, as well as motions for other practicable confinement arrangements. The Court REFERRED these applications and motions to the respective trial courts where the petitioners’ criminal cases were pending. The trial courts were directed to conduct the necessary proceedings and resolve these incidents with utmost dispatch. The proceedings before the Supreme Court were considered closed and terminated.
The Court held that it is not a trier of facts and that a direct invocation of its original jurisdiction is generally proscribed to prevent inordinate demands on its time and to observe the hierarchy of courts. It emphasized that the entitlement to bail, especially for those charged with offenses punishable by reclusion perpetua, is a question of fact that requires a summary hearing to determine if the evidence of guilt is strong—a function properly within the competence of the trial courts. This principle similarly applied to motions for other confinement arrangements, which also necessitate the reception and evaluation of evidence. The Court declined to rule on the other complex issues raised, noting that the separate opinions of the Justices would address them, and focused on the procedural aspect of referring the factual determinations to the proper forum.