GR L 66939; (January, 1987) (Digest)
G.R. Nos. L-66939-41, January 10, 1987
The People of the Philippines, petitioner, vs. The Intermediate Appellate Court and Angelito Alivia y Abalos, respondents.
FACTS
Accused Angelito Alivia was charged before the CFI of Isabela with three capital offenses: two counts of assault upon an agent of a person in authority with murder using an illegally possessed firearm (for the killings of Lt. Cesar Rumbaoa and Pat. Elpidio Sagun) and one count of murder using an illegally possessed firearm (for the killing of Atty. Norberto Maramba). The cases were consolidated as they arose from a single incident at the Azarcon Restaurant on June 4, 1982. The prosecution alleged that Alivia, having lost a barangay election where Atty. Maramba was counsel for the winning opponent, was present at the restaurant with his own group. Atty. Maramba arrived later with his group, which included Lt. Rumbaoa. After a conversation, Alivia, without warning, shot Atty. Maramba in the back of the head as he returned to his table. He then successively shot Lt. Rumbaoa and Pat. Sagun, who were present and armed but were caught by surprise.
ISSUE
The core issue is whether the evidence of guilt for the capital offenses charged is strong, thereby justifying the denial of the accused’s application for bail.
RULING
The Supreme Court granted the petition, set aside the decision of the Intermediate Appellate Court (IAC), and reinstated the trial court’s orders denying bail. The legal logic centers on the standard for granting bail in capital offenses. Under the Rules of Court, when an accused is charged with a capital offense, bail becomes a matter of discretion and should be denied if the evidence of guilt is strong. The IAC erred in granting bail after a mere summary examination of the records. The Supreme Court, upon review, found that the trial court correctly determined the evidence of guilt to be strong based on the established facts.
The Court emphasized that the killings were attended by treachery, qualifying the crimes to murder. For Atty. Maramba, treachery was present as he was shot suddenly from behind while unarmed and turning away, with no opportunity to defend himself. For the two peace officers, the attack was also sudden and unexpected; they were shot in rapid succession despite being armed, with one victim’s service firearm still found holstered, indicating an inability to offer any defense. This deliberate and surprising method of attack ensured the execution of the crimes without risk to the accused. Consequently, the proof being strong for these capital offenses, the accused is not entitled to bail as a matter of right. The discretion to deny bail was properly exercised by the trial court.