JYZEL CRIS B.

FACTOR 2023036031
FINAL DIGEST COMPILATION

Rule 111: Prosecution of Civil Actions

1. Heirs of Eduardo Simon v. Elvin Chan, G.R. No. 157547, February 23, 2011.
2. Supreme Transportation Liner, Inc. v. Antonio San Andres, G.R. No. 200444, August
15, 2018.
3. Lee Pue Liong v. Chua Pue Chin Lee, G.R. No. 181658, August 7, 2013.
4. Philippine Rabbit Bus Lines, Inc. v. People, G.R. No. 147703, April 14, 2004.
5. Jose Burgos, Jr. v. Spouses Eladio SJ Naval, G.R. No. 219468, June 8, 2016.
6. Josephine Sanches v. Far East Bank & Trust Company, G.R. No. 155309,
November 15, 2005.
7. Dr. Encarnacion Lumantas v. Hanz Calapiz, G.R. No. 163753, January 15, 2015.
8. Republic v. Court of Appeals, G.R. No. 116463, June 10, 2003.
9. Elizalde S. Co v. Munoz, Jr. G.R. No. 181986, December 4, 2013.
10. Republic v. Court of Appeals, G.R. No. 116463, June 10, 2003.
11. People v. Alfredo Morales, G.R. No. 206832, January 21, 2015.
12. People v. Benjie Consorte, G.R. No. 194068, November 26, 2014.
13. Maria Aurora Mathay v. People, G.R. No. 218964, June 30, 2020.
14. Meynardo Beltran v. People, G.R. No. 137576, June 30, 2020.
15. James Capili v. People, G.R. No. 183805, July 3, 2013.
16. Rafael Jose-Consing, Jr. v. People, G.R. No. 161075, July 15, 2013.
17. Dreamwork Construction, Inc. v. Cleofe Janiola, G.R. No. 184861, June 30, 2009.
18. People v. Victoria Arambulo, G.R. No. 186597, June 17, 2015.
19. San Miguel Properties, Inc. v. Sec. Hernando Perez, G.R. No. 166836, September
4, 2013.
20. Alsons Development and Investment Corporation v. The Heirs of Romeo Confesor,
G.R. No. 212567, September 19, 2018.
 Rule 112: Preliminary Investigation

1. Senator Jinggoy Ejercito Estrada v. Ombudsman, G.R. No. 212140-41, January

21, 2015.
2. Rolito Go v. The Court of Appeals, G.R. No. 101837, February 11, 1992.
3. Esmael Orquinaza v. People, G.R. No. 165596, November 17, 2005.
4. Alejandro Miranda v. People, G.R. No. 232192, June 22, 2020.
5. Department of Justice v. Teodulo Nano Alaon, G.R. No. 189596, April 23, 2014.
6. Johanne Edward Labay v. Sandiganbayan, G.R. Nos. 235937-40, July 23, 2018.
7. Francisco S. Tatad v. Sandiganbayan, G.R. No. 72335-39, March 21, 1988.
8. Saturnino Ocampo v. Hon. Ephrem Abando, G.R. No. 176830, February 11,
2014.
9. Alma Camoro Pahkiat v. Ombudsman, G.R. No. 223972, November 3, 2020.
10. Mario Relampagos, et al., v. Sandiganbayan, G.R. No. 235480, January 27,
2021.
11. Hasegawa v. Giron, G.R. No. 184536, August 12, 2013.
12. Gina Villa Gomez v. People, G.R. No. 216824, November 10, 2020.
13. Socorro Ongkingco v. Kazuhiro Sugiyama, G.R. No. 217787, September 18,
2019.
14. Barry Lanier v. People, G.R. No. 189176, March 19, 2014.
15. Liza Maza v. Hon. Evelyn Turla, G.R. No. 187094, February 15, 2017.
16. People v. Court of Appeals, G.R. No. 126005, January 21, 1999.
17. Alfredo Mendoza v. People, G.R. No. 197293, April 21, 2014.
18. Amando Inocentes v. People, G.R. No. 205963-64, July 7, 2016.
19. People v. Romy Lim, G.R. No. 231989, September 4, 2018.
20. People v. Eduardo Lacdan, G.R. No. 208472, October 14, 2019.
1. Senator Jinggoy Ejercito Estrada v. Ombudsman, G.R. No. 212140-41, January 21,
2015.
2. Rolito Go v. The Court of Appeals, G.R. No. 101837, February 11, 1992.
3. Esmael Orquinaza v. People, G.R. No. 165596, November 17, 2005.
4. Alejandro Miranda v. People, G.R. No. 232192, June 22, 2020.
5. Department of Justice v. Teodulo Nano Alaon, G.R. No. 189596, April 23, 2014.
6. Johanne Edward Labay v. Sandiganbayan, G.R. Nos. 235937-40, July 23, 2018.
7. Francisco S. Tatad v. Sandiganbayan, G.R. No. 72335-39, March 21, 1988.
8. Saturnino Ocampo v. Hon. Ephrem Abando, G.R. No. 176830, February 11, 2014.
9. Alma Camoro Pahkiat v. Ombudsman, G.R. No. 223972, November 3, 2020.
10. Mario Relampagos, et al., v. Sandiganbayan, G.R. No. 235480, January 27, 2021.
11. Hasegawa v. Giron, G.R. No. 184536, August 12, 2013.
12. Gina Villa Gomez v. People, G.R. No. 216824, November 10, 2020.
13. Socorro Ongkingco v. Kazuhiro Sugiyama, G.R. No. 217787, September 18, 2019.
14. Barry Lanier v. People, G.R. No. 189176, March 19, 2014.
15. Liza Maza v. Hon. Evelyn Turla, G.R. No. 187094, February 15, 2017.
16. People v. Court of Appeals, G.R. No. 126005, January 21, 1999.
17. Alfredo Mendoza v. People, G.R. No. 197293, April 21, 2014.
18. Amando Inocentes v. People, G.R. No. 205963-64, July 7, 2016.
19. People v. Romy Lim, G.R. No. 231989, September 4, 2018.
20. People v. Eduardo Lacdan, G.R. No. 208472, October 14, 2019.
 Rule 113: Arrest

1. De Lima v. Guerrero, GR 229781, 10 October 2017

2. Okabe v. Gutierrez GR 150185, 27 May 2004
3. Maza v. Turla GR 187094, 15 February2017
4. Allado v. Diokno GR 113630, 5 May 1994
5. Joey Pestilos v. Moreno Generos, G.R. No. 182601, November 10, 2014.
6. Mario Veridiano y Sapi v. People, G.R. No. 200370, June 7, 2017.
7. Domingo Agayao Macad v. People, G.R. No. 227366, August 1, 2018.
8. George Antiquera v. People, G.R. No. 180661, December 11, 2013.
9. Alejandro Miranda v. People, G.R. No. 232192, June 22, 2020.
10. People v. Ardo Bacero, G.R. No. 208527, July 20, 2016.
11. People v. Geraldo Moreno, G.R. No. 191759, March 2, 2020.
12. People v. Jaynard Agustin, G.R. No. 247718, March 3, 2021.

1. De Lima v. Guerrero, GR 229781, 10 October 2017

Facts:
In Senator Leila M. De Lima, et al. case, the petitioner, along with Rafael Marcos Z.
Ragos and Ronnie Palisoc Dayan, faced charges of violating Section 5 in relation to
Sections 3(jj), 26(b), and 28 of Republic Act No. 9165, known as the Comprehensive
Dangerous Drugs Act of 2002. The allegations claimed that between November
2012 and March 2013, De Lima, then serving as Secretary of the Department of
Justice, and Ragos, who was the Officer-in-Charge of the Bureau of Corrections,
conspired with Dayan to demand, solicit, and extort funds from high-profile inmates
at the New Bilibid Prison (NBP) to finance De Lima's senatorial campaign. The funds
were purportedly obtained from the inmates' involvement in illegal drug trading,
which was facilitated through the use of mobile phones and other electronic devices.

The case was filed with the Regional Trial Court (RTC) of Muntinlupa City,
specifically Branch 204, under Judge Juanita Guerrero. De Lima challenged the
jurisdiction of the RTC and the sufficiency of the Information by filing a Motion to
Quash. Despite this motion, the RTC issued a warrant for her arrest, prompting De
Lima to file a Petition for Certiorari and Prohibition with the Supreme Court, arguing
that the jurisdiction belonged to the Sandiganbayan rather than the RTC.

Issue:
1. Does the RTC have jurisdiction over the offense charged against De Lima?
2. Did the RTC commit grave abuse of discretion in issuing the warrant of arrest
against De Lima despite the pending Motion to Quash?
3. Is the Information filed against De Lima sufficient to charge her with the crime of
Illegal Drug Trading?

Ruling:
1. The Supreme Court ruled that the RTC does not have jurisdiction over the
offense charged against De Lima. The case falls within the jurisdiction of the
Sandiganbayan because the offense was allegedly committed in relation to her
office as Secretary of Justice.

2. The Supreme Court found that the RTC committed grave abuse of discretion in
issuing the warrant of arrest against De Lima without first resolving the Motion to
Quash. The RTC should have determined its jurisdiction before proceeding with
the issuance of the warrant.

3. The Supreme Court held that the Information filed against De Lima was
insufficient to charge her with the crime of Illegal Drug Trading. The Information
failed to allege the essential elements of the offense, such as the identities of the
buyer and seller, the object and consideration of the sale, and the delivery and
payment of the drugs.

The Sandiganbayan has exclusive jurisdiction over cases involving public officials
with Salary Grade 27 or higher when the offense is committed in relation to their
office.

The Information against De Lima explicitly stated that she committed the offense by
taking advantage of her public office, thereby establishing a close connection
between the offense and her official functions. This falls squarely within the
jurisdiction of the Sandiganbayan as provided under Section 4 of Presidential
Decree No. 1606, as amended by Republic Act No. 8249.

The RTC's issuance of the warrant of arrest without resolving the Motion to Quash
constituted grave abuse of discretion. The RTC should have first determined
whether it had jurisdiction over the case before proceeding with the issuance of the
warrant. The failure to do so rendered the issuance of the warrant arbitrary and
capricious. The Information was defective as it did not allege the essential elements
of the crime of Illegal Drug Trading.

For an Information to be sufficient, it must clearly and accurately allege the elements
of the offense charged. In this case, the Information failed to specify the identities of
the buyer and seller, the object and consideration of the sale, and the delivery and
payment of the drugs, which are necessary to establish the crime of Illegal Drug
Trading.
2. Okabe v. Gutierrez GR 150185, 27 May 2004

Facts:
In Okabe v. Gutierrez, petitioner Teresita Tanghal Okabe, a widow residing in Japan,
sought to nullify the orders issued by Judge Pedro de Leon Gutierrez of the Regional
Trial Court (RTC) of Pasay City, Branch 119.

The case arose from a complaint filed by Cecilia Maruyama on December 29, 1999,
accusing Okabe and Lorna Tanghal of estafa. Maruyama claimed that on December 11,
1998, she entrusted Okabe with 11,410,000 Japanese Yen (approximately PHP
3,993,500) for door-to-door delivery from Japan to the Philippines.

According to the allegations, Okabe failed to deliver the entrusted money, initially
denied receiving it, and later returned only USD 1,000 through Tanghal. After reviewing
the evidence, the City Prosecutor of Pasay City determined there was probable cause
for estafa and filed an Information against Okabe on May 15, 2000. Subsequently, on
May 19, 2000, Judge Gutierrez issued a warrant for Okabe's arrest, setting a
recommended bail amount of PHP 40,000.

After posting bail, Okabe filed motions to challenge the probable cause for her arrest
and requested the lifting of a hold departure order issued against her. The trial court
denied her motions, prompting Okabe to seek relief through a petition for certiorari with
the Court of Appeals (CA).

The CA partially granted her petition, allowing her to travel to Japan under specific
conditions, but upheld the trial court's finding of probable cause. Following this, Okabe
filed a petition for review on certiorari with the Supreme Court, continuing her legal
battle against the charges.

Issue:
 Whether the trial court erred in issuing a warrant without probable cause and if it
violated Okabe's due process rights.

Ruling:
The Supreme Court granted Okabe's petition, reversed and set aside the decision of the
Court of Appeals, and nullified the orders dated August 25 and 28, 2000, as well as the
warrant of arrest issued by the respondent judge. The case was remanded to the RTC
of Pasay City, Branch 119, with instructions for the respondent judge to determine the
existence or non-existence of probable cause for Okabe's arrest based on the complete
records, as required under Section 8(a), Rule 112 of the Revised Rules on Criminal
Procedure.

The Supreme Court emphasized that the trial judge must personally determine the
existence of probable cause for the issuance of a warrant of arrest, which is a duty that
cannot be delegated to the investigating prosecutor. The judge must consider not only
the resolution of the investigating prosecutor but also the affidavits, counter-affidavits,
and other documentary evidence submitted during the preliminary investigation.

In this case, the respondent judge relied solely on the resolution of the investigating
prosecutor and the affidavit-complaint of Maruyama without examining the complete
records, including the affidavits of witnesses and the counter-affidavit of Okabe. This
failure constituted a grave abuse of discretion amounting to excess or lack of
jurisdiction.

The Supreme Court also noted that procedural rules, such as Section 26, Rule 114 of
the Revised Rules on Criminal Procedure, which allow an accused to challenge the
validity of their arrest even after posting bail, should be applied retroactively to pending
cases. The Court found that Okabe did not waive her right to question the
probable cause for her arrest by posting bail and seeking other reliefs from the
trial court.

3. Maza v. Turla GR 187094, 15 February2017

Facts:
The case "Maza v. Turla" concerns petitioners Liza L. Maza, Saturnino C. Ocampo,
Teodoro A. Casiño, and Rafael V. Mariano, who are all former House of
Representatives members from different party-list groups. On December 14, 2006,
Police Senior Inspector Arnold M. Palomo submitted three murder cases involving the
petitioners and 15 other individuals to the Provincial Prosecutor of Cabanatuan City,
Nueva Ecija.

The cases involved the deaths of Carlito Bayudang, Jimmy Peralta, and Danilo Felipe,
who were allegedly killed by the petitioners and others due to their affiliation with the
rival AKBAYAN Party List. The petitioners were subpoenaed to testify in February 2007,
but they filed a motion to quash the complaint and subpoena, arguing that the
preliminary investigation was irregular and violated their due process rights.

Despite their objections, the panel of investigating prosecutors found probable cause
and filed Informations for murder and kidnapping with murder in April 2008. The
petitioners sought judicial determination of probable cause, leading to the dismissal of
the Guimba case but not the Palayan cases.

Judge Evelyn A. Turla of the Regional Trial Court of Palayan City remanded the
Palayan cases for further preliminary investigation, citing procedural irregularities. The
petitioners then filed a Petition for Certiorari and Prohibition with the Supreme Court,
seeking to nullify Judge Turla's orders and dismiss the cases against them.

Issue:
 Whether the petitioners violated the principle of hierarchy of courts by directly
filing their petition with the Supreme Court? No.
  Whether Judge Turla acted with grave abuse of discretion by remanding the
cases to the Provincial Prosecutor for further preliminary investigation? Yes.
 Whether the admissibility of evidence can be ruled upon during a preliminary
investigation? No.

Ruling:
1. The Supreme Court ruled that the petitioners did not violate the principle of
hierarchy of courts due to the compelling circumstances of the case.

The Supreme Court recognized that although the principle of hierarchy of courts
typically mandates that cases be initiated in lower courts, exceptions can be
made. In this instance, the petitioners were serving party-list representatives, and
their possible arrest and imprisonment could hinder their ability to serve their
constituents. This situation created a compelling reason for them to seek direct
access to the Supreme Court.

2. The Court found that Judge Turla acted with grave abuse of discretion by
remanding the cases for further preliminary investigation.

The Court highlighted that the determination of probable cause is a judicial

function that must be based on the judge's personal evaluation of the
prosecutor's report and supporting documents. Judge Turla's decision to remand
the cases for further preliminary investigation encroached upon the exclusive
function of the prosecutors and lacked legal basis. The judge should have
either dismissed the case, issued a warrant of arrest, or required additional
evidence.

3. The Court held that the admissibility of evidence cannot be ruled upon
during a preliminary investigation.

The Court reiterated that a preliminary investigation is not a trial on the merits but
merely a determination of whether there is sufficient ground to engender a well-
founded belief that a crime has been committed and that the respondent is
probably guilty. Therefore, the admissibility of evidence should not be ruled upon
during this stage, as it is a matter to be addressed during the trial.

4. Allado v. Diokno GR 113630, 5 May 1994

Facts:

The case "Allado v. Diokno" involves petitioners Diosdado Jose Allado and Roberto
L. Mendoza, lawyers and partners at the law firm Salonga, Hernandez, and Allado.
They faced accusations from the Presidential Anti-Crime Commission (PACC) of
orchestrating the kidnapping and murder of German national Eugen Alexander Van
Twest.
These allegations stemmed from an extrajudicial confession by Security Guard
Escolastico Umbal, a former Philippine Constabulary member, who claimed that he,
along with ex-policeman Rolando Gamatero, AFPCIG Agent Roberto Santiago, and
SPO2 Sergio Antonino, kidnapped Van Twest on June 16, 1992, and later killed him.
Following this confession, PACC operatives executed a search warrant at Santiago's
residences, resulting in multiple arrests and the recovery of a blue Nissan Pathfinder
and various firearms.

The case was then raised to the Department of Justice, which issued a subpoena to
the petitioners. Despite their requests for additional documents and the inhibition of
the panel of prosecutors, the petitioners were charged with kidnapping with murder.

The Regional Trial Court of Makati, presided by Judge Roberto C. Diokno, issued a
warrant for their arrest without bail. The petitioners sought relief from the Supreme
Court, arguing that there was no probable cause for their arrest and that the
evidence against them was insufficient and flawed.

Issue:
1. Whether there was a probable cause to justify the issuance of a warrant of arrest
against petitioners Diosdado Jose Allado and Roberto L. Mendoza?
2. Whether the respondent judge act with grave abuse of discretion in issuing the
warrant of arrest without personally examining the evidence?

Ruling:
1. The Supreme Court ruled that there was no probable cause to justify the
issuance of a warrant of arrest against the petitioners.

The Supreme Court emphasized that the determination of probable cause is a

function of the judge, who must personally evaluate the evidence submitted. In
this case, the Court found that the evidence presented was insufficient to
establish probable cause against the petitioners.

The Court noted several inconsistencies and improbabilities in the extrajudicial

confession of Security Guard Escolastico Umbal, which was the primary basis for
the charges. For instance, the claim that Van Twest's body was completely
burned to ashes using gasoline and rubber tires was deemed highly improbable.

Additionally, the Court pointed out that Van Twest's counsel continued to
represent him in legal proceedings even after his alleged death, casting further
doubt on the veracity of the claims. The Court also criticized the undue haste in
the filing of the information and the inordinate interest of the government in
securing a warrant for the arrest of the accused without bail. The Court reiterated
that the purpose of the Bill of Rights is to protect individuals against arbitrary and
discriminatory use of political power and that the right to personal liberty and
security takes precedence over the State's right to prosecute
 2. The Court found that the respondent judge acted with grave abuse of discretion
in issuing the warrant of arrest without personally examining the evidence by
relying solely on the certification of the prosecutors without personally examining
the evidence, and thus, the warrant of arrest was set aside.

5. Joey Pestilos v. Moreno Generos, G.R. No. 182601, November 10, 2014.

Facts:
The case involves petitioners Joey M. Pestilos, Dwight Macapanas, Miguel Gaces, Jerry
Fernandez, and Ronald Muñoz, who were involved in an altercation with Atty. Moreno
Generoso on February 20, 2005, around 3:15 a.m. on Kasiyahan Street, Barangay Holy
Spirit, Quezon City. After the incident, Atty. Generoso reported it to the Central Police
District, Station 6. Desk Officer SPO1 Primitivo Monsalve sent SPO2 Dominador Javier
to the scene, who, along with Airforce personnel, arrived less than an hour later to find
Atty. Generoso severely beaten; he identified the petitioners as his attackers.

The police officers "invited" the petitioners to the Batasan Hills Police Station for
investigation. During the inquest proceeding, the City Prosecutor of Quezon City
charged the petitioners with attempted murder.

The petitioners filed an Urgent Motion for Regular Preliminary Investigation, arguing that
their warrantless arrest was invalid as the police officers had no personal knowledge of
the crime.

The Regional Trial Court (RTC) denied their motion, and the Court of Appeals (CA)
affirmed the RTC's decision. The petitioners then brought the case to the Supreme
Court.

Issue:
 Whether the petitioners were validly arrested without a warrant?

Ruling:

The Supreme Court denied the petition and upheld the RTC's order. The Court ruled
that the warrantless arrest of the petitioners was valid and that the criminal proceedings
against them should proceed.

The Court elucidated that the validity of a warrantless arrest under Section 5(b), Rule
113 of the Revised Rules of Criminal Procedure requires that an offense has just been
committed and that the arresting officer has probable cause to believe, based on
personal knowledge of facts or circumstances, that the person to be arrested has
committed it. In this case, the police officers arrived at the scene less than an hour
after the alleged mauling, observed Atty. Generoso's injuries, and were informed by
him that the petitioners were the perpetrators. The petitioners did not deny their
involvement when confronted by the police. These circumstances provided the police
officers with probable cause to effect a warrantless arrest.

The Court also explained that the term "invited" in the Affidavit of Arrest was construed
as an authoritative command, indicating an intention to arrest. Lastly, the Court found
no impropriety in the RTC's order denying the motion for preliminary investigation, as it
sufficiently stated the reasons for its denial.
6. Mario Veridiano y Sapi v. People, G.R. No. 200370, June 7, 2017.

Facts:

Veridiano y Sapi was charged with illegal possession of dangerous drugs under Article
II, Section 11 of Republic Act No. 9165. The incident took place on January 15, 2008, in
Nagcarlan, Laguna. A concerned citizen alerted PO3 Esteves at the Nagcarlan Police
Station that an individual known as "Baho," later identified as Veridiano, was headed to
San Pablo City to acquire illegal drugs. In response to this information, Chief of Police
June Urquia directed PO1 Guillermo Cabello and PO2 Alvin Vergara to establish a
checkpoint at Barangay Taytay, Nagcarlan. Around 10:00 a.m., the officers stopped a
passenger jeepney, instructed the passengers to get out and lift their shirts. During this
search, they discovered a tea bag containing marijuana on Veridiano, resulting in his
arrest and subsequent charges.

Veridiano pleaded not guilty during his arraignment on October 9, 2008. The trial court
found him guilty beyond reasonable doubt and sentenced him to imprisonment of twelve
years and one day to twenty years, along with a fine of P300,000.

Veridiano appealed, arguing that his arrest was illegal and that the evidence obtained
was inadmissible as it was the "fruit of a poisonous tree."

The Court of Appeals affirmed the trial court's decision, stating that Veridiano was
caught in flagrante delicto and had waived his right to question the arrest by entering a
plea. Veridiano then filed a Petition for Review on Certiorari with the Supreme Court,
asserting that his constitutional rights against unreasonable searches and seizures were
violated.

Issue:
1. Was there a valid warrantless arrest of Mario Veridiano y Sapi?
2. Was there a valid warrantless search conducted against Mario Veridiano y Sapi?
3. Is there enough evidence to sustain Mario Veridiano y Sapi's conviction for illegal
possession of dangerous drugs?

Ruling:

The Supreme Court ruled that the warrantless arrest of Veridiano was unlawful. For a
warrantless arrest to be valid under Rule 113, Section 5 of the Revised Rules of
Criminal Procedure, the person must be caught in flagrante delicto, or there must be
personal knowledge of facts indicating that the person has just committed an offense. In
this case, Veridiano was merely a passenger in a jeepney and did not exhibit any
suspicious behavior that would justify a warrantless arrest. The police acted solely on a
tip, which is insufficient to constitute probable cause.

The Court also found that the warrantless search was invalid. A valid search
incidental to a lawful arrest requires that the arrest precedes the search. Since the
arrest was unlawful, the subsequent search was also invalid. The Court emphasized
that the right against unreasonable searches and seizures is guaranteed by the
Constitution, and any evidence obtained in violation of this right is inadmissible.

Furthermore, the Court rejected the argument that Veridiano's lack of resistance
constituted consent to the search. Consent to a warrantless search must be
unequivocal, specific, and intelligently given, free from any coercion. The environment in
which the search was conducted was coercive, negating any claim of consent.

Lastly, the Court noted that the extensive search conducted at the checkpoint exceeded
the allowable limits of warrantless searches. Routine inspections at checkpoints
should be limited to visual searches unless there is probable cause to believe that a
crime has been committed. The police officers had no probable cause other than the tip
they received, making the search and the evidence obtained from it inadmissible.

7. Domingo Agayao Macad v. People, G.R. No. 227366, August 1, 2018.

Facts:
In the case of Domingo Agyao Macad v. People of the Philippines, the petitioner,
Domingo Agyao Macad, was charged with violating Section 5, Article II of Republic Act
(R.A.) No. 9165, commonly referred to as the Comprehensive Dangerous Drugs Act of
2002.

This incident took place on November 27, 2011, when off-duty Police Officer 1 (PO1)
Davies Falolo boarded a bus that was headed to Bontoc, Mountain Province. At a stop
in Botbot, Macad got on the same bus, bringing with him a carton and a woven bag from
Sagada.

PO1 Falolo became suspicious that the baggage might contain marijuana because of its
unusual smell and shape. Once they arrived in Bontoc, Macad got off the bus at Caluttit,
while Falolo went to look for a vendor to buy load for his mobile phone. After not finding
any vendors, he decided to take a tricycle to Caluttit, where Macad happened to get into
the same tricycle. When they reached the Community Police Assistance Center
(COMPAC) circle, PO1 Falolo halted the tricycle and proceeded to contact SPO2
Gaspar Suagen for assistance.

When asked to open his baggage, Macad ran away but was apprehended and brought
to the Municipal Police Station. The baggage revealed 17 bricks of marijuana weighing
a total of 16 kilograms.
The Regional Trial Court (RTC) found Macad guilty and sentenced him to life
imprisonment and a fine of P500,000. The Court of Appeals (CA) affirmed the RTC's
decision.

Macad appealed to the Supreme Court, arguing that his arrest and the search were
unlawful and that the chain of custody was compromised.

Issue:
1. Whether the warrantless arrest of Domingo Agyao Macad lawful? Yes
2. Whether the search and seizure of the marijuana bricks valid? Yes
3. Whether the chain of custody of the seized drugs properly established? Yes

Ruling:

The Supreme Court found that PO1 Falolo had probable cause to conduct a warrantless
arrest and search. The distinct smell of marijuana emanating from Macad's baggage
and the irregular shape of the bags provided reasonable grounds for suspicion.

The Court held that the arrest was lawful under Section 5 (a) and (b), Rule 113 of the
Rules of Court, which allows warrantless arrests when a person is caught in flagrante
delicto or when an offense has just been committed, and the officer has personal
knowledge of facts indicating that the person committed it.

The Court also noted that the search was valid as an incident to a lawful arrest and that
the chain of custody rule was substantially complied with. The marking, photographing,
and inventory of the seized items were conducted in the presence of the required
witnesses, ensuring the integrity and evidentiary value of the drugs.

The Court dismissed Macad's arguments regarding procedural lapses, stating that any
minor discrepancies did not affect the overall integrity of the evidence. The petition was
denied, and the CA's decision was affirmed in toto.

8. George Antiquera v. People, G.R. No. 180661, December 11, 2013.

Facts:

On January 13, 2004, George Codes Antiquera and Corazon Olivenza Cruz were
charged by the second Assistant City Prosecutor of Pasay City with illegal possession
of drug paraphernalia before the Regional Trial Court (RTC) in Criminal Case 04-0100-
CFM. Cruz was tried in absentia after failing to appear for her bail hearing.

The prosecution presented evidence indicating that on February 11, 2004, around 4:45
a.m., a police visibility patrol, including officers PO1 Gregorio Recio, PO1 Laurence
Cabutihan, P/Insp. Eric Ibon, and PO1 Rodelio Rania, was conducted on David Street,
Pasay City. During their patrol, the officers observed two unidentified men exiting house
number 107-C and entering a jeep, which raised their suspicions. The officers
approached the residence and peered through a partially opened door, where they saw
Antiquera with an improvised tooter and a pink lighter, while Cruz held aluminum foil
and an improvised burner. The officers then entered the house, identified themselves,
and arrested both individuals. They also discovered a wooden jewelry box containing
various drug paraphernalia, which a forensic chemical officer later confirmed tested
positive for methamphetamine hydrochloride, commonly known as "shabu." Antiquera
contended that the police had forcibly entered his home and planted the evidence.
On July 30, 2004, the RTC convicted Antiquera and Cruz, sentencing them to a prison
term of six months and one day to two years and four months, in addition to a fine of
P10,000 each. The court rejected Antiquera's claim of illegal arrest, citing the credible
testimonies of the police officers. The Court of Appeals (CA) upheld the RTC's ruling on
September 21, 2007. Subsequently, Antiquera sought acquittal from the Supreme
Court.

Issue:
 Whether the Court of Appeals err in finding George Antiquera guilty beyond
reasonable doubt of illegal possession of drug paraphernalia based on the police
officers' evidence?
 Whether the warrantless arrest and subsequent search and seizure conducted
by the police officers valid?

Ruling:
The Supreme Court reversed the decision of the Court of Appeals and acquitted George
Antiquera of the crime charged due to lack of evidence sufficient to establish his guilt
beyond reasonable doubt. The Court also ordered the cancellation and release of the
bail bond he posted for his provisional liberty.

The Supreme Court found that the circumstances did not constitute a valid warrantless
arrest. The police officers' suspicion arose from seeing two unidentified men rush out of
the house, but they did not pursue the men. Instead, they focused on the house without
any immediate indication of a crime. The officers admitted that they pushed the door
open to peek inside, which did not reveal any activity justifying their entry.

The Court emphasized that no crime was plainly exposed to the officers' view, making
the arrest illegal. Consequently, the search and seizure that followed were also illegal,
rendering the seized drug paraphernalia inadmissible as evidence. Since the
paraphernalia constituted the corpus delicti of the crime, the Court had no choice but to
acquit Antiquera. The Court also noted that a waiver of an illegal warrantless arrest
does not imply a waiver of the inadmissibility of evidence obtained from such an arrest.

9. Alejandro Miranda v. People, G.R. No. 232192, June 22, 2020.

Facts:
Alejandro C. Miranda was charged with rape through sexual assault under Article 266-A
(2) of the Revised Penal Code, as amended, in relation to Republic Act No. 7610. The
incident occurred on April 6, 2006, in Muntinlupa City, where Miranda allegedly inserted
his penis into the anal orifice of a six-year-old boy, AAA. The City Prosecutor of
Muntinlupa City filed the Information on April 12, 2006. Miranda, assisted by Atty. Melita
Pilar P. Brias of the Public Attorney's Office, pleaded not guilty during his arraignment
on May 17, 2006. The Regional Trial Court (RTC) granted Miranda's Motion to Reduce
Bail, setting it at P70,000.00 for a cash bond or P80,000.00 for a bail bond. During the
trial, it was established that AAA was playing in front of Miranda's house when he was
pulled inside, undressed, and sexually assaulted. AAA reported the incident to his
stepfather, BBB, who then informed the barangay police. Miranda was subsequently
invited to the barangay hall and detained after AAA identified him as the assailant.
Miranda denied the charges, claiming he treated AAA as his own son. On February 12,
2010, the RTC convicted Miranda, sentencing him to an indeterminate penalty of six
years and one day of prision mayor to twelve years and one day of reclusion temporal.
Miranda was also ordered to pay P25,000.00 each in civil and moral damages. The
Court of Appeals (CA) affirmed the conviction on July 30, 2014, with modifications to the
damages awarded. Miranda's subsequent motions for reconsideration were denied,
leading him to file a Petition for Review on Certiorari with the Supreme Court.

Issue:
1. Was Alejandro C. Miranda's warrantless arrest and detention lawful?
2. Was Miranda properly convicted of rape through sexual assault under Article
266-A (2) of the Revised Penal Code, as amended, in relation to Republic Act
No. 7610?

Ruling:
1. The Supreme Court ruled that Miranda's warrantless arrest and detention were
not lawful.
2. The Supreme Court affirmed Miranda's conviction for rape through sexual assault
but modified the penalty and damages awarded.

Ratio:
1. The Supreme Court found that Miranda's arrest did not fall within the purview of a
lawful warrantless arrest under Rule 113, Section 5 of the Revised Rules of
Criminal Procedure. The barangay police did not witness the crime, nor did they
have personal knowledge of the facts indicating Miranda was the offender. The
information they acted upon from AAA's stepfather did not constitute personal
knowledge.

Consequently, Miranda should have been entitled to a preliminary investigation

before the Information was filed. However, the absence of a preliminary
investigation did not affect the trial court's jurisdiction or the validity of the
Information. By voluntarily pleading not guilty, Miranda waived his right to
question any irregularity in his arrest or the absence of a preliminary
investigation.
 2. The Supreme Court held that Miranda was correctly convicted of rape through
sexual assault under Article 266-A (2) of the Revised Penal Code, as amended,
in relation to Republic Act No. 7610. The victim's testimony was categorical and
credible, detailing how Miranda inserted his penis into the victim's anus.

The Court emphasized that rape, regardless of the manner of its commission, is
a heinous crime causing incalculable damage to the victim's dignity. The Court
modified the penalty to an indeterminate sentence of 12 years, 10 months, and
21 days of reclusion temporal as the minimum, to 15 years, six months, and 20
days of reclusion temporal as the maximum. Additionally, the Court increased the
civil indemnity, moral damages, and exemplary damages to P50,000.00 each,
with all damages subject to a legal interest rate of six percent per annum from
the finality of the decision until fully paid.

10. People v. Ardo Bacero, G.R. No. 208527, July 20, 2016.

Facts:
In the case of "People of the Philippines vs. Ardo Bacero y Casabon" (G.R. No.
208527), the accused-appellant, Ardo Bacero y Casabon, faced charges for the
special complex crime of Robbery with Homicide. The incident took place on March
24, 2003, in Taytay, Rizal, where Bacero, accompanied by several unidentified
accomplices, attacked Virgilio San Juan, Jr. (Jun) and his girlfriend, Juliet Dumdum-
Bunot, during a picnic. Bacero inflicted a stab wound to Jun's face and stole his
cellphone, while Juliet was restrained and robbed of her possessions. Later, Jun's
lifeless body was discovered by security guards.

Juliet identified Bacero as one of the assailants based on her familiarity with his face
from seeing him around her neighborhood. Bacero was arrested and initially denied
involvement but later confessed to the crime.

During the trial, Bacero claimed mistaken identity, alibi, and torture by the police.
The Regional Trial Court (RTC) of Antipolo City found Bacero guilty and sentenced
him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC's decision,
leading to Bacero's appeal to the Supreme Court.

Issue:
1. Whether the identification of Ardo Bacero y Casabon as one of the perpetrators
is credible and sufficient for conviction.
2. Whether the extra-judicial confession made by Bacero is admissible in evidence.
3. Whether the defenses of mistaken identity, alibi, and torture can exonerate
Bacero from the charges.
4. Whether the penalty and damages awarded by the lower courts are appropriate.

Ruling:
 1. The Supreme Court affirmed the conviction of Ardo Bacero y Casabon for
Robbery with Homicide.
2. The extra-judicial confession made by Bacero was deemed inadmissible due to
non-compliance with custodial investigation requirements.
3. The defenses of mistaken identity, alibi, and torture were found to be without
merit.
4. The penalty of reclusion perpetua without eligibility for parole was upheld, and
the damages awarded were modified.

Ratio:
The Supreme Court upheld Bacero's conviction based on the positive identification
by Juliet, who had a clear opportunity to observe the assailants during the crime.
The Court noted that despite her initial shock, Juliet's identification of Bacero was
consistent and credible. The extra-judicial confession was ruled inadmissible as it
was not made in the presence of a lawyer or any authorized person as required by
law. However, the Court emphasized that the positive identification by an eyewitness
is sufficient for conviction even without the confession.

Bacero's defenses of mistaken identity, alibi, and torture were dismissed due to lack
of credible evidence. The Court also found that the aggravating circumstance of
abuse of superior strength was present, justifying the penalty of reclusion perpetua
without eligibility for parole. The damages awarded were adjusted to reflect accurate
computations based on competent proof, ensuring fair compensation for the heirs of
the victim.

11. People v. Geraldo Moreno, G.R. No. 191759, March 2, 2020.

Facts:
The case involves the People of the Philippines as the plaintiff-appellee and Gerald
Moreno y Tazon as the accused-appellant. The incident took place on November 16,
2001, in Manila, where Gerald Moreno was accused of murdering Cecil Mijares by
inflicting multiple stab wounds.

The Regional Trial Court (RTC) of Manilamfound Moreno guilty of murder,

sentencing him to reclusion perpetua and ordering him to pay various damages to
the heirs of the victim.

The Court of Appeals (CA) affirmed this decision on August 27, 2009. The
prosecution's case was primarily based on the eyewitness testimony of Adelriza
Mijares, the victim's wife, who identified Moreno as the assailant. The defense
argued that Moreno was at home during the incident and denied any involvement.

The RTC rejected the defense's alibi and denial, emphasizing the credibility of the
eyewitness testimony. The CA upheld the RTC's decision, leading to Moreno's
appeal to the Supreme Court.
 Issue:
1. Did the trial court err in ruling that the positive testimony of the prosecution's
witness prevailed over the defense of alibi and denial?
2. Was the identification and arrest of the appellant conducted in a manner that
violated his constitutional rights?
3. Was the award of damages by the RTC appropriate and justified?

Ruling:
1. The Supreme Court ruled that the positive testimony of the prosecution's witness,
despite minor inconsistencies, prevailed over the defense of alibi and denial.
2. The Court found that the identification and arrest of the appellant were conducted
properly and did not violate his constitutional rights.
3. The Court affirmed the award of damages but made modifications, increasing
moral damages to PHP 75,000.00, unearned income to PHP 1,378,944.00,
awarding temperate damages of PHP 50,000.00 in lieu of actual damages, and
granting exemplary damages of PHP 75,000.00.

Ratio:
The Supreme Court emphasized that denial is inherently a weak defense compared
to positive testimony, which is more reliable and credible. The Court noted that for
an alibi to be successful, the accused must prove it was physically impossible for
them to be at the crime scene, which Moreno failed to do.

The Court also highlighted that minor inconsistencies in the eyewitness testimony
did not undermine its overall credibility. Regarding the identification and arrest, the
Court stated that a police line-up is not indispensable for proper identification, and
the totality of circumstances test confirmed the reliability of the eyewitness
identification.

The Court emphasized that any objections regarding the arrest procedure must be
presented before the arraignment, which Moreno did not do, thereby waiving his
right to challenge it. The Court determined that treachery was a factor in the attack,
categorizing the crime as murder. Adjustments to the damages awarded were made
in accordance with established legal precedents, ensuring fair compensation for the
victim's heirs.

12. People v. Jaynard Agustin, G.R. No. 247718, March 3, 2021.

Facts:
The case involves Jaynard Agustin y Paraggua (Agustin), who was charged for the
crime of Rape with Homicide against a 12-year-old minor, AAA, in Cagayan on
November 1, 2010.

The Information was filed on November 3, 2010, and Agustin pleaded not guilty
during arraignment. The prosecution called several witnesses to testify, including
AAA's mother, BBB; Dr. Francisco Romulo D. Villaflor, the medico-legal officer; Atty.
Luis Donato, Jr., who provided counsel during the custodial investigation; Barangay
Captain Alfredo Ruam; and PO3 Joel Mora, the investigating officer. Dr. Villaflor's
autopsy findings indicated that AAA died from asphyxia caused by strangulation and
showed signs of having been subjected to forced sexual intercourse.

Agustin's extrajudicial confession, taken by PO3 Mora and witnessed by Atty.

Donato, Jr., detailed his admission of raping and killing AAA. The defense presented
Agustin, who denied involvement and claimed he did not understand the confession
due to his illiteracy.

The Regional Trial Court (RTC) found Agustin guilty and sentenced him to reclusion
perpetua, awarding damages to AAA's heirs. The Court of Appeals (CA) affirmed the
conviction but modified the damages. Agustin appealed to the Supreme Court,
arguing the inadmissibility of his extrajudicial confession and insufficient evidence of
guilt.

Issue:
 Whether Agustin's extrajudicial confession admissible in evidence? No.
 Whether the prosecution proves Agustin's guilt beyond reasonable doubt?

Ruling:
 The Supreme Court ruled that Agustin's extrajudicial confession was
inadmissible.

 The Supreme Court found that the prosecution failed to prove Agustin's guilt
beyond reasonable doubt.

Ratio:
The Supreme Court held that Agustin's extrajudicial confession was obtained in
violation of his constitutional rights under custodial investigation. The Court
emphasized that the rights to remain silent and to have competent and independent
counsel must be effectively communicated and understood by the accused. The
confession showed only a perfunctory reading of rights without ensuring Agustin's
understanding, especially given his illiteracy and inability to read or write. The Court
also found that Atty. Donato, Jr. did not provide effective legal assistance, as he
failed to ensure Agustin understood his rights and the consequences of his
confession. The confession was further deemed unreliable due to the multiple
translations involved. Without the extrajudicial confession, the remaining evidence,
including the medico-legal report, was insufficient to establish Agustin's guilt beyond
reasonable doubt.
 The Court underscored the principle that the prosecution must prove guilt beyond
reasonable doubt, and the weakness of the defense does not relieve the prosecution
of this burden. Consequently, the Court acquitted Agustin and ordered his immediate
release.

Rule 114: Bail

1. Miranda v. Tuliao, G.R. No. 158763, March 31, 2006
2. Juan Ponce Enrile v. Sandiganbayan, G.R. No. 213847, August 18, 2015.
3. People v. Manuel Escobar, G.R. No. 214300, July 26, 2017.
4. Renato David v. Editha Agbay, G.R. No. 199113, March 18, 2015.
5. Miguel Paderanga v. Court of Appeals, G.R. No. 115407, August 28, 1995.
6. Ricardo Manotoc, Jr. v. Court of Appeals, G.R. No. L-62100, May 30, 1986.
7. Regino Sy Catiis v. Court of Appals, G.R. No. 153979, February 6, 2006.
8. People v. Manuel Escobar, G.R. No. 214300, July 26, 2017.
9. Jose Antonio Leviste v. The Court of Appeals, G.R. No. 189122, May 17, 2010.
10. People v. Novo Tanes, G.R. No. 240596, April 3, 2019.
11. Reynaldo Arbas Recto v. People, G.R. No. 236461, December 5, 2018.

1. Miranda v. Tuliao, G.R. No. 158763, March 31, 2006

Facts:
The case of "Miranda v. Tuliao" involves petitioners Jose C. Miranda, Alberto P.
Dalmacio, and Romeo B. Ocon, who were involved in the murder of Vicente
Bauzon and Elizer Tuliao, the latter being the son of respondent Virgilio M. Tuliao.

The incident occurred on March 8, 1996, in Purok Nibulan, Ramon, Isabela, where
two burnt cadavers were discovered. Initially, two informations for murder were
filed against several police officers, including SPO2 Rodel Maderal, who later
executed a sworn confession implicating the petitioners.
 Acting Presiding Judge Wilfredo Tumaliuan issued warrants of arrest against the
petitioners on June 25, 2001.

The petitioners filed motions to quash the warrants, which were denied by Judge
Tumaliuan. Later, Judge Anastacio D. Anghad took over the case and quashed the
warrants, leading to the dismissal of the criminal cases.

Respondent Tuliao filed a petition for certiorari, mandamus, and prohibition, which
led to the Court of Appeals reversing Judge Anghad's orders and reinstating the
criminal cases and warrants of arrest. The petitioners then sought review by the
Supreme Court.

Issue:
 Whether the Court of Appeals erred in reversing and setting aside the orders of
Judge Anghad and reinstating the orders of Judge Tumaliuan?
 Whether the Court of Appeals erred in directing the reinstatement of the criminal
cases and the issuance of warrants of arrest against the petitioners?
 Does the reinstatement of the criminal cases constitute double jeopardy?

Ruling:

1. The Supreme Court denied the petition for review and affirmed the decision of
the Court of Appeals, which found that Judge Anghad acted with grave abuse of
discretion in quashing the warrants of arrest and dismissing the criminal cases.

2. The Supreme Court upheld the reinstatement of the criminal cases and the
issuance of warrants of arrest against the petitioners.

3. The Supreme Court ruled that the reinstatement of the criminal cases does not
constitute double jeopardy as the cases were dismissed before arraignment and
upon the petitioners' express motion.

Ratio:
The Supreme Court explained the distinction between custody of the law and
jurisdiction over the person. Custody of the law is required for applications for bail
but not for other judicial reliefs.
 The Court found that Judge Anghad's quashing of the warrants based on a
pending petition for review with the Secretary of Justice and political climate
considerations constituted grave abuse of discretion.

The Court emphasized that probable cause needs only to show that a crime has
likely been committed and by the suspects, not requiring clear and convincing
evidence of guilt.

The Court also noted that the dismissal of the criminal cases based on a decision
in another case with different accused was improper. The reinstatement of the
criminal cases does not constitute double jeopardy as the petitioners had not been
arraigned, and the dismissal was upon their motion. The Court ordered the transfer
of the cases to the Regional Trial Court of Manila and directed Judge Anghad to
issue warrants of arrest for the petitioners.

2. Juan Ponce Enrile v. Sandiganbayan, G.R. No. 213847, August 18, 2015

Facts:
In the case of "Enrile v. Sandiganbayan," Senator Juan Ponce Enrile, the
petitioner, challenged the Sandiganbayan's denial of his motion for bail in a
plunder case.

Enrile was charged with plunder on June 5, 2014, by the Office of the Ombudsman
for his alleged involvement in the diversion and misuse of appropriations under the
Priority Development Assistance Fund (PDAF). Enrile filed an Omnibus Motion on
June 10, 2014, and a Supplemental Opposition on June 16, 2014, requesting bail if
probable cause was found against him.

The Sandiganbayan denied his motion on July 3, 2014, citing its prematurity as
Enrile had not yet surrendered or been placed under custody. Enrile voluntarily
surrendered on the same day and was confined at the Philippine National Police
(PNP) General Hospital. He subsequently filed a Motion for Detention at the PNP
General Hospital and a Motion to Fix Bail on July 7, 2014, arguing that the
prosecution had not established strong evidence of his guilt, that he was not a
flight risk, and that his age and physical condition should be considered.

The Sandiganbayan denied his Motion to Fix Bail on July 14, 2014, and his Motion
for Reconsideration on August 8, 2014. Enrile then filed a petition for certiorari with
the Supreme Court, arguing that the Sandiganbayan's resolutions were issued with
grave abuse of discretion.
 Issue:
 Whether Enrile is entitled to bail as a matter of right before the judgment of the
Sandiganbayan.
 Whether the prosecution failed to show that Enrile, if convicted, is punishable by
reclusion perpetua.
 Whether the prosecution failed to show that the evidence of Enrile's guilt is
strong.
 Whether Enrile should be granted bail on humanitarian grounds due to his age
and medical condition.

Ruling:
The Supreme Court granted Enrile's petition for certiorari, annulling and setting
aside the Sandiganbayan's resolutions dated July 14, 2014, and August 8, 2014.
The Court ordered the provisional release of Enrile upon posting a cash bond of
P1,000,000.00 and directed his immediate release from custody unless detained
for another lawful cause.

The Supreme Court ruled that bail protects the right of the accused to due process
and to be presumed innocent until proven guilty. The primary purpose of bail is to
ensure the accused's appearance at trial.

The Court emphasized that bail may be granted as a matter of right or discretion,
depending on the nature of the offense and the strength of the evidence. In Enrile's
case, the Court found that his advanced age and frail health justified his admission
to bail. The Court noted that Enrile's medical conditions, including chronic
hypertension, atherosclerotic cardiovascular disease, arrhythmia, asthma-COPD
overlap syndrome, and other ailments, required special medical attention that
could not be adequately provided in detention.

The Court also considered Enrile's social and political standing, his voluntary
surrender, and his respect for legal processes, concluding that he was not a flight
risk. The Court balanced the scales of justice by ensuring Enrile's appearance at
trial while safeguarding his right to due process and presumption of innocence.

3. People v. Manuel Escobar, G.R. No. 214300, July 26, 2017.

Facts:
The case involves Manuel Escobar, who was involved in the kidnap-for-ransom of
Mary Grace Cheng-Rosagas, her bodyguard Valentin B. Torres, and her driver
Dionisio F. Burca on June 18, 2001, in front of Malcolm Hall, University of the
Philippines, Diliman, Quezon City. The victims were taken by armed men in police
 uniforms and detained in various locations, including Club Solvento, a resort
owned by Escobar. The victims were released after a ransom of P15,000,000.00
was paid. Cancio Cubillas, a member of the kidnapping group, became a state
witness and associated Escobar as an adviser to the group leader, Rolando
Villaver.

Escobar was arrested on February 14, 2008, and filed his first petition for bail on
June 3, 2008, which was denied by the Regional Trial Court (RTC) on October 6,
2008, and affirmed by the Court of Appeals (CA) on March 8, 2011.

Escobar filed a second petition for bail on January 27, 2012, after his co-accused,
Rolando Fajardo, was granted bail. The RTC denied this second petition on April
26, 2012, citing res judicata. Escobar appealed, and the CA granted his petition on
March 24, 2014, directing the RTC to determine the appropriate bail for his
provisional liberty. The prosecution, through the Office of the Solicitor General,
filed a petition for review before the Supreme Court, arguing that res judicata
should apply.

Issue:
 Whether Manuel Escobar's second petition for bail is barred by res judicata? No.
 Whether Escobar should be granted bail? Yes.

Ruling:

The Supreme Court held that res judicata does not apply to interlocutory orders in
criminal proceedings, such as an order denying a petition for bail. Res judicata
applies only to final judgments in civil cases. The Court emphasized that an
interlocutory order, like the denial of a bail petition, does not attain finality and can
be revisited if new matters warrant a different view.

The Court also noted that the right to bail is rooted in the presumption of innocence
and that bail may be granted if the evidence of guilt is not strong. The Court found
that the same evidence used to grant bail to Escobar's co-accused, Rolando
Fajardo, should similarly apply to Escobar, especially since both were implicated
based on the same testimony by state witness Cubillas, which was deemed
unreliable. The Court concluded that denying Escobar's second bail petition on the
ground of res judicata was incorrect and that his provisional liberty should be
granted in the interest of justice.

4. Renato David v. Editha Agbay, G.R. No. 199113, March 18, 2015.
 Facts:
Renato M. David, the petitioner, moved to Canada in 1974 and later became a
Canadian citizen through naturalization. After retiring, David and his wife returned
to the Philippines, where they purchased a 600-square meter beachfront lot in
Tambong, Gloria, Oriental Mindoro, in 2000, and built a house on it. In 2004, they
found out that the property was public land within the salvage zone. On April 12,
2007, David submitted a Miscellaneous Lease Application (MLA) for the land to the
Department of Environment and Natural Resources (DENR) through the
Community Environment and Natural Resources Office (CENRO) in Socorro,
falsely claiming to be a Filipino citizen.

Editha A. Agbay, the private respondent, opposed the application, arguing that
David, as a Canadian citizen, was disqualified from owning land. She also filed a
criminal complaint for falsification of public documents under Article 172 of the
Revised Penal Code (RPC) against David. On October 11, 2007, David re-
acquired his Filipino citizenship under Republic Act No. 9225 (R.A. 9225). Despite
this, the Office of the Provincial Prosecutor found probable cause to indict David
for falsification on January 8, 2008. David's MLA was rejected by CENRO on June
3, 2008, and his petition for review was denied by the Department of Justice (DOJ)
on July 26, 2010.

An information for falsification was filed, and a warrant of arrest was issued.
David's motion for re-determination of probable cause was denied by the Municipal
Trial Court (MTC) of Socorro on March 22, 2011, and his motion for
reconsideration was also denied.

David then filed a petition for certiorari with the Regional Trial Court (RTC) of
Pinamalayan, which was denied on October 8, 2011. David subsequently sought
review from the Supreme Court.

Issue:
 Can the petitioner be indicted for falsification for representing himself as a
Filipino in his Public Land Application despite his subsequent re-acquisition of
Philippine citizenship under R.A. 9225? Yes.
 Did the MTC properly deny the petitioner's motion for re-determination of
probable cause on the ground of lack of jurisdiction over the person of the
accused (petitioner)? Yes.

Ruling:
The Supreme Court held that R.A. 9225, known as the "Citizenship Retention and
Re-acquisition Act of 2003," distinguishes between re-acquisition and retention of
 Philippine citizenship. The law allows natural-born Filipinos who lost their
citizenship by naturalization in a foreign country to re-acquire their Philippine
citizenship upon taking an oath of allegiance. However, this re-acquisition does not
retroactively affect the status of the petitioner at the time he filed his MLA. At the
time of filing, David was still a Canadian citizen, and his subsequent re-acquisition
of Philippine citizenship did not cure the defect in his MLA, which was void ab
initio. The elements of falsification under Article 172 of the RPC were present, as
David made an untruthful statement in a public document, claiming to be a Filipino
citizen when he was not. The MTC's finding of probable cause for falsification was
upheld.
Regarding jurisdiction, the Supreme Court clarified that while custody of the law is
required for applications for bail, it is not necessary for other reliefs sought by the
accused. By filing a motion for re-determination of probable cause, David
sought affirmative relief and thus submitted himself to the jurisdiction of the court.
The MTC's erroneous statement about lacking jurisdiction over David's person did
not constitute grave abuse of discretion, and the RTC correctly denied the petition
for certiorari.

5. Miguel Paderanga v. Court of Appeals, G.R. No. 115407, August 28, 1995.

Facts:
The case concerns about petitioner Miguel P. Paderanga, who was involved as a
co-conspirator in a multiple murder case involving the Bucag family in Gingoog City
in 1984. Initially, eight suspects were indicted, but only one, Felipe Galarion, was
apprehended, tried, and convicted before escaping from prison. The other
suspects remained at large. Felizardo ("Ely") Roxas, a former employee of
Paderanga, implicated him as the mastermind behind the murders in a signed
affidavit, which he later retracted. Following the inhibition of the City Prosecutor of
Cagayan de Oro City, State Prosecutor Henrick F. Gingoyon was designated to
handle the case. Paderanga was charged in a second amended information dated
October 6, 1992. He challenged his inclusion as a co-accused up to the Supreme
Court, which sustained the filing of the second amended information against him.

Before an arrest warrant could be served, Paderanga filed a motion for admission
to bail on October 28, 1992, while confined at the Cagayan Capitol College
General Hospital due to "acute costochondritis." The trial court set the hearing for
November 5, 1992, where Assistant Prosecutor Erlindo Abejo appeared for the
prosecution and waived any further presentation of evidence. The trial court
granted bail in the amount of P200,000.00, which Paderanga posted the following
day. The prosecution's motion for reconsideration was denied, and Prosecutor
Gingoyon elevated the matter to the Court of Appeals, which annulled the trial
 court's resolution and order, citing grave abuse of discretion. Paderanga then
appealed to the Supreme Court.

Issue:
 Whether Paderanga was constructively under the custody of the law when he
filed his motion for admission to bail? Yes.
 Whether the trial court erred in granting bail without giving the prosecution a
reasonable opportunity to oppose the bail application? No.

Ruling:

The Supreme Court held that Paderanga was constructively under the custody of
the law when he filed his motion for admission to bail. Although he was not
physically arrested, his actions, including filing the motion and informing the court
of his whereabouts, indicated his submission to the court's jurisdiction. The Court
emphasized that bail is intended to secure an accused's provisional liberty and
cannot be posted before custody is acquired by judicial authorities. The Court
found that Paderanga's situation was akin to being in constructive custody, as he
was confined in a hospital and had not attempted to evade arrest.

Regarding the prosecution's opportunity to oppose the bail application, the Court
noted that the Regional State Prosecutor's Office had received the motion for bail
on the same day it was filed, giving them more than a week to prepare. The Court
found that the prosecution, through Assistant Prosecutor Abejo, had waived the
presentation of further evidence and submitted the matter to the trial court's
discretion. The trial court had conducted a proper hearing and had given the
prosecution a reasonable opportunity to present its case. The Court also
highlighted that the prosecution's delay of over six months in filing the certiorari
petition was unreasonable.

The Supreme Court reversed the Court of Appeals' decision and reinstated the trial
court's resolution and omnibus order granting bail to Paderanga.

6. Ricardo Manotoc, Jr. v. Court of Appeals, G.R. No. L-62100, May 30, 1986.
Facts:
Petitioner Ricardo L. Manotoc, Jr., a principal stockholder of Trans-Insular
Management, Inc. and Manotoc Securities, Inc., faced criminal charges for estafa.
The charges stemmed after a Torrens title submitted to Manotoc Securities, Inc.
was suspected to be fake, leading six clients to file complaints.
 The criminal cases were filed in the Court of First Instance of Rizal and were
assigned to Judges Serafin E. Camilon and Ricardo L. Pronove, Jr.

Manotoc was granted bail, with FGU Insurance Corporation acting as surety. On
March 1, 1982, Manotoc filed motions in the trial courts seeking permission to
travel to the United States for business purposes.

Both motions were denied, with the courts citing a lack of urgency and potential
risks to the surety. Manotoc's subsequent request to the Immigration
Commissioner to lift a travel restriction was also denied. He then filed a petition for
certiorari and mandamus with the Court of Appeals, which dismissed the petition.
Manotoc sought review by the Supreme Court, which also denied his motion for
leave to travel abroad.

Issue:
 Does a person facing a criminal indictment and provisionally released on bail
have an unrestricted right to travel?

Ruling:
The Supreme Court ruled that a person facing a criminal indictment and
provisionally released on bail does not have an unrestricted right to travel. The
petition for review was dismissed, with costs against the petitioner. (When a
person is facing a criminal charge and has been released on bail, this right is not
absolute)

The Court held that the power to prohibit a person admitted to bail from leaving the
Philippines is a necessary consequence of the nature and function of a bail bond.
Rule 114, Section 1 of the Rules of Court defines bail as the security required for
the release of a person in custody, ensuring their appearance in court. The
condition to make oneself available at all times when required by the court is a
valid restriction on the right to travel.

The Court cited "People v. Uy Tuising," which established that allowing an accused
to leave the jurisdiction would render court orders and processes nugatory. The
Court also differentiated this case from "People vs. Shepherd," where the accused
showed urgent necessity for travel, the duration, and the surety's consent.

Manotoc failed to demonstrate these factors. The Court emphasized that the
constitutional right to travel is not absolute and can be impaired by a lawful court
order, as provided in Section 5, Article IV of the 1973 Constitution. The trial court's
order releasing Manotoc on bail constituted such a lawful order.
7. Regino Sy Catiis v. Court of Appals, G.R. No. 153979, February 6, 2006.

Facts:
On May 28, 2001, Catiis filed a letter-complaint against the private respondents for
violation of Article 315, No. 2(a) of the Revised Penal Code in relation to
Presidential Decree No. 1689 (syndicated estafa) and other related offenses. The
private respondents, except for Margielyn Tafalla, submitted joint counter-affidavits
denying the charges.

On October 10, 2001, Assistant City Prosecutor Alessandro D. Jurado found

probable cause for syndicated estafa against the private respondents and Tafalla,
recommending no bail.

An Information was filed on the same day, and the case was raffled to Branch 96
of the Regional Trial Court of Quezon City. Judge Lucas P. Bersamin issued an
order on November 7, 2001, finding probable cause and approving the
recommendation that the charge be non-bailable.

However, on December 18, 2001, Judge Bersamin reconsidered his earlier order,
declaring the offense bailable and fixing the bail amount at P150,000.00 each.
Catiis filed a petition for certiorari with the Court of Appeals (CA), which was
denied. The CA upheld the orders of Judge Bersamin and Executive Judge Monina
A. Zenarosa, who approved the surety bonds and ordered the release of the
private respondents.

Issue:
 Whether the Court of Appeals erred in sustaining the validity of the order ruling
that there should be at least five persons charged under Section 1 of Presidential
Decree No. 1689.
 Whether the grant of bail violated Section 7, Rule 114 of the Revised Rules of
Criminal Procedure.
 Whether the approval of the bail bond by Executive Judge Monina A. Zenarosa
violated Section 17, Rule 114 of the Revised Rules of Criminal Procedure.

Ruling:
The Supreme Court denied the petition for review on certiorari and affirmed the
decision of the Court of Appeals dated June 14, 2002. The Court found no grave
abuse of discretion in the orders issued by Judge Bersamin and Judge Zenarosa.
The Court ruled that the crime charged was not committed by a syndicate as
defined under the law, and therefore, the penalty of life imprisonment to death
 could not be imposed. Consequently, the private respondents were entitled to bail
as a matter of right.

The Supreme Court held that under Section 1 of P.D. No. 1689, a syndicate is
defined as consisting of five or more persons formed with the intention of carrying
out the unlawful or illegal act, transaction, enterprise, or scheme. Since the
Information specifically charged only four persons, the crime charged was not
committed by a syndicate. The Court emphasized that the law must be considered
as a whole, and the definition provided by the law is controlling. The Court also
noted that the Information did not allege any aggravating circumstances, and
therefore, the lesser penalty of reclusion temporal was imposable in case of
conviction.

Under Section 13, Article III of the 1987 Philippine Constitution, all persons,
except those charged with offenses punishable by reclusion perpetua when
evidence of guilt is strong, shall before conviction be bailable by sufficient sureties.
Since the imposable penalty on the private respondents was reclusion temporal,
they were entitled to bail as a matter of right. The Court also found no irregularity in
the approval of the bail bond by Judge Zenarosa, as there was no evidence to
rebut the presumption that official duty had been regularly performed.

8. People v. Manuel Escobar, G.R. No. 214300, July 26, 2017.

Facts:
The case involves Manuel Escobar, who was involved in the kidnap-for-ransom of
Mary Grace Cheng-Rosagas, her bodyguard Valentin B. Torres, and her driver
Dionisio F. Burca on June 18, 2001, in front of Malcolm Hall, University of the
Philippines, Diliman, Quezon City. The victims were taken by armed men in police
uniforms and detained in various locations, including Club Solvento, a resort
owned by Escobar. The victims were released after a ransom of P15,000,000.00
was paid. Cancio Cubillas, a member of the kidnapping group, became a state
witness and associated Escobar as an adviser to the group leader, Rolando
Villaver.

Escobar was arrested on February 14, 2008, and filed his first petition for bail on
June 3, 2008, which was denied by the Regional Trial Court (RTC) on October 6,
2008, and affirmed by the Court of Appeals (CA) on March 8, 2011.

Escobar filed a second petition for bail on January 27, 2012, after his co-accused,
Rolando Fajardo, was granted bail. The RTC denied this second petition on April
26, 2012, citing res judicata. Escobar appealed, and the CA granted his petition on
 March 24, 2014, directing the RTC to determine the appropriate bail for his
provisional liberty. The prosecution, through the Office of the Solicitor General,
filed a petition for review before the Supreme Court, arguing that res judicata
should apply.

Issue:
 Whether Manuel Escobar's second petition for bail is barred by res judicata? No.
 Whether Escobar should be granted bail? Yes.

Ruling:

The Supreme Court held that res judicata does not apply to interlocutory orders in
criminal proceedings, such as an order denying a petition for bail. Res judicata
applies only to final judgments in civil cases. The Court emphasized that an
interlocutory order, like the denial of a bail petition, does not attain finality and can
be revisited if new matters warrant a different view.

The Court also noted that the right to bail is rooted in the presumption of innocence
and that bail may be granted if the evidence of guilt is not strong. The Court found
that the same evidence used to grant bail to Escobar's co-accused, Rolando
Fajardo, should similarly apply to Escobar, especially since both were implicated
based on the same testimony by state witness Cubillas, which was deemed
unreliable. The Court concluded that denying Escobar's second bail petition on the
ground of res judicata was incorrect and that his provisional liberty should be
granted in the interest of justice.

9. Jose Antonio Leviste v. The Court of Appeals, G.R. No. 189122, May 17, 2010.

Facts:
Petitioner Jose Antonio Leviste was charged with murdering Rafael de las Alas but
was convicted of homicide by the Regional Trial Court (RTC) in Makati City. He
received an indeterminate sentence of six years and one day of prision mayor as a
minimum, up to 12 years and one day of reclusion temporal as a maximum.

Leviste appealed his conviction to the Court of Appeals (CA) and filed an urgent
application for admission to bail pending appeal, citing his advanced age and
health condition, and claiming no risk of flight.

The CA denied his application, emphasizing the need for grave caution in granting
bail pending appeal and noting that Leviste failed to show that his health condition
was severe enough to warrant bail.
 The CA conducted a preliminary evaluation of the case and found no substantial
reason to overturn the evidence of Leviste's guilt.

Leviste's motion for reconsideration was denied, prompting him to file a special
civil action for certiorari under Rule 65 of the Rules of Court, alleging grave abuse
of discretion by the CA in denying his application for bail.

Issue:
In an application for bail pending appeal by an appellant sentenced by the trial
court to a penalty of imprisonment for more than six years, does the discretionary
nature of the grant of bail pending appeal mean that bail should
automatically be granted absent any of the circumstances mentioned in the
third paragraph of Section 5, Rule 114 of the Rules of Court?

Ruling:
The Supreme Court dismissed the petition, affirming the Court of Appeals' decision
to deny Leviste's application for bail pending appeal. The Court directed the CA to
resolve and decide the appeal of petitioner Jose Antonio Leviste with dispatch.

The Supreme Court held that the grant of bail pending appeal is discretionary and
should be exercised with grave caution and only for strong reasons. The Court
emphasized that the discretion to grant bail pending appeal is not automatically
negated by the absence of the circumstances listed in the third paragraph of
Section 5, Rule 114 of the Rules of Court. The appellate court must consider all
relevant circumstances, including the nature of the offense, the character and
reputation of the appellant, and whether the appeal raises a substantial question of
law or fact. The Court found that the CA did not act with grave abuse of discretion
in denying Leviste's application for bail, as it carefully assessed his health
condition and the merits of his case. The Court also noted that the denial of bail
pending appeal is consistent with the principle that bail should be granted only
where it is uncertain whether the accused is guilty or innocent, and that the
presumption of innocence is rebutted upon conviction.

10. People v. Novo Tanes, G.R. No. 240596, April 3, 2019.

Facts:
The respondent, Novo Tanes y Belmonte, was charged with violating Section 5,
Article II of Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of
2002. This charge arose from an incident on December 14, 2010, in DARBCI
Subdivision, National Highway, General Santos City, where Tanes allegedly sold a
 sachet containing 0.0296 grams of methamphetamine hydrochloride (shabu) to an
undercover buyer for Php500.00.

Tanes pleaded not guilty and subsequently filed a petition for bail on April 10,
2015. The Regional Trial Court (RTC) of General Santos City, Branch 23,
conducted hearings on October 7, 2015, November 4, 2015, and February 3,
2017.

On March 31, 2017, the RTC granted Tanes' application for bail, citing doubts
about the chain of custody of the seized drugs. The prosecution's motion for
reconsideration was denied on June 27, 2017. The People of the Philippines then
filed a petition for certiorari with the Court of Appeals (CA), which upheld the RTC's
decision on February 21, 2018, and denied the motion for reconsideration on July
11, 2018. The case was then brought before the Supreme Court.

Issue:
 Did the Court of Appeals err in affirming the RTC's order granting Tanes'
application for bail?
 Did the RTC commit grave abuse of discretion by requiring the presence of three
witnesses during the buy-bust operation and the actual seizure of the drug?

Ruling:
The Supreme Court denied the petition, affirming the decisions of the RTC and the
CA. The Court ruled that the RTC did not commit grave abuse of discretion in
granting Tanes' application for bail due to doubts about the chain of custody of the
seized drugs.

The Supreme Court emphasized the constitutional right to bail, as enshrined in

Section 13, Article III of the 1987 Philippine Constitution, which states that all
persons, except those charged with offenses punishable by reclusion perpetua
when evidence of guilt is strong, shall be bailable.

The Court noted that Tanes was charged with an offense punishable by life
imprisonment, making bail a matter of judicial discretion if the evidence of guilt is
not strong. The RTC conducted the required summary hearings and found that the
prosecution failed to establish a strong evidence of guilt due to lapses in the chain
of custody. Specifically, the RTC and CA found that the required witnesses (media
representative, DOJ representative, and elected public official) were not present
during the actual buy-bust operation and seizure, but were merely called to sign
the inventory sheet. This non-compliance with Section 21, Article II of R.A. 9165
created doubts about the integrity and identity of the seized drugs.
 The Supreme Court upheld the RTC's reliance on the case of People v. Jehar
Reyes, which mandates the presence of the three witnesses during the buy-bust
operation to prevent planting of evidence and frame-ups. The Court concluded that
the prosecution's failure to comply with the chain of custody rules negated the
strong evidence of Tanes' guilt, justifying the grant of bail.

11. Reynaldo Arbas Recto v. People, G.R. No. 236461, December 5, 2018.

Facts:
On February 18, 2011, in Gen. Mariano Alvarez, Cavite, Reynaldo Arbas Recto
(Recto) was accused of murdering Margie Carlosita (Carlosita) by hitting her on the
head and body with a hard object, resulting in her death.

The Information for Murder filed against Recto alleged that the crime was qualified
by treachery, evident premeditation, and abuse of superior strength.

Recto's former counsel filed a Petition for Bail on May 23, 2011, but the Regional
Trial Court (RTC) of Bacoor City, Branch 89, denied it on April 11, 2014, based on
the testimony of Joshua Emmanuel Rabillas (Rabillas), Carlosita's son, who
identified Recto as the perpetrator.

The RTC found the evidence of guilt strong and required Recto to take the witness
stand to refute it. After the prosecution rested its case, Recto filed a Demurrer to
Evidence on June 22, 2015, which the RTC denied on December 22, 2015.

Recto then filed a Motion to Fix Bail on April 27, 2016, arguing that the evidence
only supported a charge of Homicide, not Murder.

The RTC denied this motion on June 8, 2016, and Recto's subsequent motion for
reconsideration was also denied on January 29, 2016.

Recto then filed a petition for certiorari with the Court of Appeals (CA), which
upheld the RTC's decision.

Recto's motion for reconsideration was denied by the CA on January 11, 2018,
leading him to file a Petition for Review on Certiorari with the Supreme Court.
 Issue:
 Did the Court of Appeals err in dismissing Recto's petition for certiorari?

Ruling:
The Supreme Court granted Recto's Petition for Review on Certiorari, reversing
and setting aside the CA's Decision dated June 29, 2017, and Resolution dated
January 11, 2018. The Court ordered the RTC of Bacoor City, Branch 89, to fix the
bail for Reynaldo Arbas Recto.

The Supreme Court found that the RTC committed grave abuse of discretion in
denying Recto's Motion to Fix Bail. The Court emphasized that under Section 13,
Article III of the 1987 Philippine Constitution, all persons, except those charged
with offenses punishable by reclusion perpetua when evidence of guilt is strong,
are entitled to bail. The RTC initially acted within its jurisdiction in denying Recto's
Petition for Bail based on the evidence presented.

However, after the prosecution rested its case, the evidence only supported a
charge of Homicide, not Murder, as the testimony of Rabillas indicated that the
killing occurred during a quarrel, negating the qualifying circumstances of
treachery, evident premeditation, and abuse of superior strength. The Court cited
jurisprudence, including People v. Rivera and Bernardez v. Valera, to support its
conclusion that the evidence of guilt for Murder was not strong. Therefore, the RTC
should have granted Recto's Motion to Fix Bail, making bail a matter of right for
him.