Remedial Law

Dionisio Almonte et al vs People of the Philippines

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G.R. No. 252117 – 878 Phil. 628 – Remedial Law – Criminal Procedure – Rule 114; Bail – Release of Prisoners on Humanitarian Consideration; Covid-19 Pandemic – Nelson Mandela Rules

Dionisio Almonte and his co-petitioners were alleged members of the New People’s Army (NPA) who were arrested for committing multiple murders. When the COVID-19 pandemic struck, they petitioned before the Supreme Court for them to be provisionally released on humanitarian considerations. They alleged that they are senior citizens, weakly, and some of the petitioners were also pregnant and that as such, they are most vulnerable to contract Covid in the congested prison system.

The petitioners justified their direct filing with the Supreme Court by invoking the Supreme Court’s “equity jurisdiction”. They also argued, among others, that the State’s response to the pandemic was not sufficient and that the UN Standard Minimum Rules for the Treatment of Prisoners (Nelson Mandela Rules) imposes a duty on the part of the State to protect the health and safety of prisoners consistent with one’s right to life.

The State, through the Solicitor General, opposed the petition on the ground that the petitioners are high-value NPA members who have committed heinous crimes.

ISSUE: Whether or not the Petition should be granted.

HELD: The Supreme Court treated the petition as a petition for bail. The petition was thus referred to the respective courts handling the specific cases being faced by each individual petitioner. The Supreme Court further emphasized that in crimes punishable by reclusion perpetua such as the crimes being faced by the petitioners, bail is a matter of discretion where the evidence of guilt is strong. The determination whether or not evidence of guilt is strong for purposes of bail is the function of the trial court. The Supreme Court is not a trier of facts. The issue on other practicable and suitable prison arrangements in view of the pandemic is likewise best resolved by the trial courts.

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