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People Vs San Diego0

The prosecution charged multiple defendants with murder and objected to their motions for bail since it had not presented all its witnesses yet. The trial court overruled the objection and granted bail, finding the evidence of guilt was not strong. The Supreme Court ruled this deprived the prosecution of due process, as the trial court should have allowed the prosecution to present all its evidence before ruling on bail. The court's discretion to grant bail in capital cases requires a summary of the prosecution's evidence be considered, and the orders granting bail here were defective because they did not include this summary.

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Jessamine Orioque
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118 views1 page

People Vs San Diego0

The prosecution charged multiple defendants with murder and objected to their motions for bail since it had not presented all its witnesses yet. The trial court overruled the objection and granted bail, finding the evidence of guilt was not strong. The Supreme Court ruled this deprived the prosecution of due process, as the trial court should have allowed the prosecution to present all its evidence before ruling on bail. The court's discretion to grant bail in capital cases requires a summary of the prosecution's evidence be considered, and the orders granting bail here were defective because they did not include this summary.

Uploaded by

Jessamine Orioque
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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People vs.

San Diego
26 SCRA 522 (1968)

Facts:
The accused were charged for murder. The prosecution and the defense agreed that the motions
for bail of the defendants would be considered in the course of the regular trial instead of in a
summary proceeding. In the course of the regular trial, after the prosecution had presented eight
witnesses, the trial court resolved the motions for bail granting the same despite the objection of
the prosecution on the ground that it still had material witnesses to present. Bail was granted on
the ground that the evidence of guilt was not strong.

Issue:
Whether or not the prosecution was deprived of procedural due process when trial court granted
bail without allowing the prosecution to present their other witnesses?

Ruling:
Yes. The prosecution was deprived of procedural due process when trial court granted bail
without allowing the prosecution to present their other witnesses.
The rule is whether the motion for bail of a defendant who is in custody for a capital offense be
resolved in a summary proceeding or in the course of a regular trial, the prosecution must be
given an opportunity to present, within a reasonable time, all the evidence that it may desire to
introduce before the court should resolve the motion for bail.
If, as in the criminal case involved in the instant special civil action, the prosecution should be
denied such an opportunity, there would be a violation of procedural due process, and the order
of the court granting bail should be considered void on that ground. The orders complained of
dated October 7, 9 and 12, 1968, having been issued in violation of procedural due process, must
be considered null and void.
The court’s discretion to grant bail in capital offenses must be exercised in the light of a
summary of the evidence presented by the prosecution; otherwise, it would be uncontrolled and
might be capricious or whimsical. Hence, the court’s order granting or refusing bail must contain
a summary of the evidence for the prosecution followed by its conclusion whether or not the
evidence of guilt is strong. The orders of October 7, 9 and 12, 1968, granting bail to the five
defendants are defective in form and substance because they do not contain a summary of the
evidence presented by the prosecution. They only contain the court’s conclusion that the
evidence of guilt is not strong. Being thus defective in form and substance, the orders
complained of cannot, also on this ground, be allowed to stand.

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