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, ET AL., RESPONDENTS.

FACTS

This case involves an urgent petition filed directly with the Supreme Court by several persons deprived of liberty (PDLs), represented by their relatives, seeking their temporary release on humanitarian grounds due to the COVID-19 pandemic. The petitioners specifically prayed for release on recognizance or, alternatively, on bail, for the duration of the public health emergency. They invoked the Court’s equity jurisdiction. All petitioners are charged with offenses punishable by death, reclusion perpetua, or life imprisonment, and one has already been convicted with an appeal pending. The petitioners had not filed the necessary bail applications in their respective trial courts, and no bail hearings had been conducted to determine if the evidence of guilt against them was strong.

ISSUE

Whether the Supreme Court can directly grant the petitioners’ prayer for temporary release on bail or recognizance on humanitarian grounds, absent the requisite bail hearings in the trial courts to determine the strength of the evidence of guilt.

RULING

No. The Supreme Court, in this Separate Opinion, concurs in the result that the petition should be referred to the proper trial courts. The petition should be treated as applications for bail/recognizance and motions for suitable confinement arrangements. The Court cannot directly grant bail or recognizance. The Constitution and statutes (Republic Act No. 10389, the Recognizance Act of 2012) prescribe a legal framework: bail is not a matter of right for those charged with capital offenses where evidence of guilt is strong. A hearing is mandatory to determine whether strong evidence of guilt exists, which is a factual inquiry. The Supreme Court is not a trier of facts and is institutionally incapable of conducting such evidentiary hearings. Equity cannot be invoked against existing law. While the case of Enrile v. Sandiganbayan granted bail without a prior hearing, that ruling was pro hac vice based on the accused’s unique circumstances (solid reputation and fragile health) and should not be taken as a general precedent. Therefore, the proper procedure is for the petitioners to seek relief from their respective trial courts, which are equipped to conduct the necessary hearings and factual determinations.