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

On April 6, 2020, several Persons Deprived of Liberty (PDLs) filed a petition before the Supreme Court seeking provisional release on recognizance or bail for the duration of the COVID-19 pandemic. The PDLs alleged they belonged to vulnerable or at-risk groups due to their medical and/or physical conditions. They prayed for their temporary release on humanitarian grounds, the creation of a Prisoner Release Committee, and the issuance of relevant ground rules. The Solicitor General’s comment disclosed that, except for one serving a sentence, all PDLs were charged with non-bailable offenses, with cases pending trial. The PDLs admitted these facts in their reply.

ISSUE

Whether the Supreme Court can grant the PDLs’ petition for provisional release on humanitarian grounds in the midst of the COVID-19 pandemic.

RULING

The petition should be denied. The Supreme Court’s duty is to apply the law, not to act as a trier of facts. The right to bail is governed by the Constitution and the Rules of Court. For offenses punishable by reclusion perpetua or life imprisonment, bail is not a matter of right and cannot be granted without a prior hearing to determine if the evidence of guilt is strong. The PDLs, charged with non-bailable offenses, raised factual issues regarding their health conditions, which require evaluation by trial courts. The unauthenticated medical certificates they submitted cannot be subject to judicial notice. Bail on humanitarian grounds, as allowed in Enrile v. Sandiganbayan, is a matter of judicial discretion based on specific circumstances, which the PDLs failed to similarly present. The proper remedy is to file petitions for bail before the Regional Trial Courts where their criminal cases are pending, as these courts are equipped to conduct the necessary summary hearings and factual determinations. While international initiatives and instruments emphasize the humane treatment of prisoners, these do not override existing statutory laws and procedural rules in the Philippines. Existing jail and prison manuals already provide guidelines for the welfare of PDLs, including those with health concerns.