Padilla v. CA
Padilla v. CA
DELFIN 1-F
RELEVANT FACTS
In an information filed before the RTC of Angeles City, Padilla was charged with violation of PD No. 1866 for
illegal possession of firearms punishable by reclusion temporal maximum to reclusion perpetua.
Padilla was released on bail. Thereafter, he was convicted as charged.
Padilla filed an appeal to CA but was DENIED.
CA cancelled his bailbond and ordered his arrest and for confinement at the New Bilibid Prison.
Padilla filed a motion for reconsideration but was DENIED by the CA.
Hence, Padilla filed a petition for review on certiorari with an application for bail praying, among others, to be
allowed to post bail for his temporary liberty. In his subsequent pleading, Padilla moved for the separate
resolution of his bail application.
ISSUE: Whether or not Padilla is entitled to bail.
RULING:
NO. Bail is a either a matter of right, or of discretion. It is a matter of right when the offense charged is not
punishable by death, reclusion perpetua or life imprisonment. On the other hand, upon conviction by the RTC of an
offense not punishable by death, reclusion perpetua or life imprisonment, bail becomes a matter of discretion.
In this case, Padilla was convicted of a crime punishable by reclusion perpetua. Applying the aforequoted rule, the
Court find Padilla not entitled to bail as his conviction clearly imports that the evidence is strong. In addition,
Administrative Circular No. 2-92, applies in this case. The circular unequivocably provides that, “when an accused is
charged with a capital offense or an offense which under the law at the time of its commission, and at the time of
the application for bail is punishable by reclusion perpetua and is out of bail and after trial is convicted by the trial
court of the offense charged, his bond shall be cancelled and the accused shall be placed in confinement pending
resolution of his appeal.” Thus, Padilla’s application must, perforce, fail as he is no longer entitled to bail.
RULING
Petition DENIED.