GR 139599; (February, 2000) (Digest)
G.R. No. 139599 February 23, 2000
ANICETO SABBUN MAGUDDATU and LAUREANA SABBUN MAGUDDATU, petitioners, vs. HONORABLE COURT OF APPEALS and PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Petitioners Aniceto and Laureana Maguddatu were charged with murder. During trial, they were granted bail. They were later convicted of the lesser crime of Homicide and sentenced to an indeterminate prison term. The judgment was promulgated in absentia, and the trial court issued an order for their arrest. While remaining at large, petitioners filed a Notice of Appeal and a motion for provisional liberty under the same bail bond pending appeal. The trial court did not resolve this motion and forwarded the records to the Court of Appeals.
The Court of Appeals ordered petitioners to show cause why their appeal should not be dismissed for their failure to submit to the court’s jurisdiction. Petitioners filed a compliance, expressing willingness to submit but explaining they believed their motion for bail pending appeal had been granted. They remained at large. The Court of Appeals subsequently denied their application for bail, ordered their arrest, and later dismissed their appeal for failure to prosecute after they continued to evade custody.
ISSUE
Whether the Court of Appeals committed grave abuse of discretion in denying petitioners’ application for bail pending appeal.
RULING
No. The Court of Appeals did not commit grave abuse of discretion. The right to bail is not absolute after conviction. Under the Rules of Court, after a judgment of conviction by the Regional Trial Court, bail becomes a matter of judicial discretion. This discretion is exercised not as a right of the accused but based on the existence of exceptional circumstances, such as the presence of a strong showing of errors leading to the conviction or a clear likelihood of reversal. Petitioners failed to present any such exceptional circumstances to justify the grant of bail as a discretionary act.
Crucially, the petitioners’ conduct militated against the favorable exercise of discretion. They remained fugitives from justice, having evaded arrest since the promulgation of their conviction. The Court emphasized that an applicant for bail must be in the custody of the law. By remaining at large despite court orders, petitioners demonstrated disrespect for judicial processes and were not entitled to the provisional liberty they sought. Their flight was a negative factor properly considered in denying bail. The petition was ultimately dismissed, as the dismissal of their appeal by the Court of Appeals rendered the issue moot.