GR 115407; (August, 1995) (Digest)
G.R. No. 115407 August 28, 1995
MIGUEL P. PADERANGA, petitioner, vs. COURT OF APPEALS and PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Petitioner Miguel P. Paderanga, former mayor of Gingoog City, was charged as a co-conspirator in an amended information for multiple murder. Before an arrest warrant could be served, he filed a motion for admission to bail while confined in a hospital. At the hearing, his counsel manifested that petitioner, though not physically arrested, submitted to the court’s jurisdiction through the IBP chapter president. The sole appearing prosecutor, Erlindo Abejo, stated the prosecution was neither supporting nor opposing the bail application, waiving the presentation of evidence. The trial court granted bail.
Subsequently, the designated State Prosecutor, Henrick Gingoyon, filed a motion for reconsideration, which was denied. He then filed a certiorari petition with the Court of Appeals, which annulled the grant of bail. The appellate court ruled petitioner was not in custody of the law at the time of his application, the charge was punishable by reclusion perpetua, and the prosecution was denied due process to oppose the bail.
ISSUE
Whether the Court of Appeals erred in annulling the trial court’s order granting bail to the petitioner.
RULING
Yes. The Supreme Court reversed the Court of Appeals and reinstated the trial court’s order granting bail. The legal logic is threefold. First, on the custody requirement, the Court ruled that by filing the bail application, petitioner voluntarily submitted to the court’s jurisdiction, placing him in the custody of the law. Custody is not limited to physical restraint but includes submission to the court’s authority.
Second, on the propriety of the grant, the Court emphasized that bail is a matter of right except when the evidence of guilt is strong for capital offenses. Here, the prosecution, through Prosecutor Abejo, explicitly waived its right to present evidence to prove the guilt was strong. By failing to present evidence at the hearing, the prosecution could not later claim the evidence was strong. The trial court did not gravely abuse its discretion in granting bail based on the record before it.
Third, on due process, the prosecution was not denied its right to be heard. It received notice of the hearing and chose, through its representative, not to present opposing evidence. The subsequent belated opposition by a different prosecutor did not invalidate the earlier waiver made in court by a competent representative. Therefore, the grant of bail was proper.