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

Petitioners are detention prisoners or pre-judgment persons deprived of liberty (PDLs) who are most vulnerable to COVID-19. They fall into two categories: sickly older people afflicted with severe medical conditions, or pregnant women, who have no access to bail as a matter of right for the crimes charged. They seek provisional liberty either on bail for a specified amount or on recognizance, invoking humanitarian considerations due to the public health emergency. They claim their plea does not fall under ordinary legal remedies and instead call for the exercise of the Court’s equity jurisdiction. They cite the ruling in Enrile v. Sandiganbayan and assert that the infringement of their rights as PDLs increases their risks from COVID-19. Respondents, through the Office of the Solicitor General, argue the issue is whether the State can provide medical care to petitioners while maintaining their confinement, and enumerate efforts to curb COVID-19 among PDLs.

ISSUE

Whether the Supreme Court should exercise its equity jurisdiction to grant petitioners provisional liberty on bail or recognizance on humanitarian grounds due to the COVID-19 pandemic.

RULING

The separate opinion delves into the nature and necessity of equity jurisdiction. It explains that the Philippine court system does not have a historical distinction between courts of common law and courts of equity, as the legal system evolved without such a division. The Civil Code mandates judges not to decline judgment due to silence or insufficiency of the law and to presume the lawmaking body intended right and justice to prevail. The opinion traces the historical development of common law and equity in England, noting their merger in the 19th century to address systemic conflicts. It clarifies that in the Philippines, jurisprudence has evolved independently, treating remedies without distinguishing between common law and equitable origins. The Court does not need to invoke a separate “equity jurisdiction” to provide equitable remedies, as flexible principles from equity have crystallized into defined rules within the legal system. The opinion implies that any relief for petitioners must be grounded in existing legal principles and rules, not a free-floating exercise of equitable discretion.