G.R. No. 129670 February 1, 2000
MANOLET O. LAVIDES, petitioner, vs. HONORABLE COURT OF APPEALS; HON. ROSALINA L. LUNA PISON, Judge Presiding over Branch 107, RTC, Quezon City; and PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioner Manolet Lavides was arrested without a warrant on April 3, 1997, following an entrapment operation. The police, acting on a report from the parents of 16-year-old Lorelie San Miguel, found the petitioner with the minor in a hotel room. An information for child abuse under R.A. No. 7610 was filed. Subsequently, nine more informations were filed based on complaints from Lorelie and three other minors, alleging petitioner engaged in sexual intercourse with them for money. The trial court found probable cause for detention in the first case and granted bail for all cases, totaling P800,000, but imposed conditions including mandatory appearance at all hearings and automatic bail forfeiture for any absence. Petitioner filed a motion to quash, which was denied, and he was arraigned. He then filed a petition for certiorari with the Court of Appeals.
The Court of Appeals partially granted the petition. It annulled the conditions requiring the accused’s mandatory presence at all hearings and the automatic forfeiture of bail for absence, finding them contrary to constitutional provisions allowing trial in absentia under certain circumstances. However, it maintained the trial court’s orders in all other respects, including the denial of the motion to quash. The appellate court deemed the issue regarding the condition making arraignment a prerequisite for bail approval as moot, as petitioner had already posted bail and been arraigned. Petitioner elevated the case to the Supreme Court.

ISSUE

The primary issues were: (1) the validity of the conditions attached to the grant of bail; (2) the propriety of the denial of the motion to quash the multiple informations; and (3) the correctness of requiring arraignment before approving bail bonds.

RULING

The Supreme Court modified the decision of the Court of Appeals. It upheld the trial court’s orders except for the condition making arraignment a prerequisite for bail approval, which it declared void. The Court ruled that while bail is a matter of right for offenses not punishable by death, reclusion perpetua, or life imprisonment, the approval of bail bonds should not be contingent upon arraignment. An accused is entitled to provisional liberty upon posting bail, and requiring arraignment first unduly restricts this right.
Regarding the conditions on attendance and automatic forfeiture, the Supreme Court reversed the Court of Appeals and reinstated the trial court’s impositions. The Court held that these conditions were valid exercises of judicial discretion to ensure the accused’s presence at trial, considering the gravity of the charges and the penalty involved. The constitutional provision on trial in absentia was not violated, as the conditions were designed to prevent unwarranted absence, not to punish justified non-appearance.
On the motion to quash, the Supreme Court affirmed its denial. It ruled that each act of sexual intercourse with a child exploited in prostitution or subjected to other sexual abuse under R.A. No. 7610 constitutes a separate and distinct offense. Therefore, filing separate informations for each incident, even if they involve the same victim, was proper and did not violate rules against duplicity of offenses. The charges were correctly based on the specific statutory framework for child protection.