GR L 1833; (May, 1949) (Digest)
G.R. No. L-1833; May 13, 1949
MEDARDO MUÑOZ, petitioner, vs. EMILIO RILLORAZA, JOSE B. BERNABE and MANUEL ESCUDERO, Associate Judges of the People’s Court, Fourth Division, respondents.
FACTS
Petitioner Medardo Muñoz was charged with treason before the People’s Court. He pleaded not guilty and applied for bail. Initially, the court set a joint hearing for both his bail application and the merits of the case, which was agreed upon by both parties. However, the hearing was postponed multiple times, often at the defense’s request or with its conformity. When the joint hearing finally commenced, Muñoz moved to separate the proceedings, requesting that his bail application be heard summarily first before continuing with the trial on the merits. The trial court denied this motion and proceeded with the joint hearing. Muñoz then filed a petition for mandamus with the Supreme Court to compel the judges to hear and decide his bail application separately and prior to the trial on the merits.
ISSUE
Whether the trial court committed an unlawful neglect of duty by refusing to conduct a separate, summary hearing on the petitioner’s application for bail before proceeding with the joint hearing on the merits, thereby warranting the issuance of a writ of mandamus.
RULING
No. The Supreme Court denied the petition. The Court held that the respondent judges did not unlawfully neglect their duty, as the joint hearing was originally agreed upon by both parties, and the delays were attributable to the petitioner’s own motions or conformity. The Court emphasized that the petitioner had waived his right to a summary hearing on bail by agreeing to the joint hearing and by consenting to repeated postponements. Furthermore, the Court ruled that the decision to allow or disallow a reversion to a separate bail hearing was within the trial court’s discretion, and such discretion cannot be controlled by mandamus. The denial was without prejudice to the petitioner seeking a prompt decision on his bail application from the proper Court of First Instance (where the case was transferred upon the abolition of the People’s Court).
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