The Supreme Court denied the accused's claim that denying him bail violated his constitutional rights. The Court held that bail is a matter of discretion for crimes punishable by reclusion perpetua, like rape, if there is strong evidence of guilt. Here, the RTC properly denied bail to the accused appealing his conviction for raping a 13-year-old girl, as the evidence against him was strong. The Court affirmed the conviction but increased the indemnity from P20,000 to P40,000.
The Supreme Court denied the accused's claim that denying him bail violated his constitutional rights. The Court held that bail is a matter of discretion for crimes punishable by reclusion perpetua, like rape, if there is strong evidence of guilt. Here, the RTC properly denied bail to the accused appealing his conviction for raping a 13-year-old girl, as the evidence against him was strong. The Court affirmed the conviction but increased the indemnity from P20,000 to P40,000.
The Supreme Court denied the accused's claim that denying him bail violated his constitutional rights. The Court held that bail is a matter of discretion for crimes punishable by reclusion perpetua, like rape, if there is strong evidence of guilt. Here, the RTC properly denied bail to the accused appealing his conviction for raping a 13-year-old girl, as the evidence against him was strong. The Court affirmed the conviction but increased the indemnity from P20,000 to P40,000.
The Supreme Court denied the accused's claim that denying him bail violated his constitutional rights. The Court held that bail is a matter of discretion for crimes punishable by reclusion perpetua, like rape, if there is strong evidence of guilt. Here, the RTC properly denied bail to the accused appealing his conviction for raping a 13-year-old girl, as the evidence against him was strong. The Court affirmed the conviction but increased the indemnity from P20,000 to P40,000.
➢ Agripino Gine, a resident of Barangay Naburacan in the Municipality of Matnog, Sorsogon
Province, accompanied his 13-year-old daughter, Merelyn, to the local police station to report a rape committed against her. ➢ Subsequently, the accused was apprehended and charged, and a provisional release bond of P25000 was granted. ➢ The Municipal Circuit Trial Court (MCTC) found the accused guilty, prompting an appeal to the Regional Trial Court (RTC). The accused requested bail, which was denied by the RTC. ➢ The accused now challenges the denial of bail, claiming that it violates his constitutional right to bail.
ISSUE:
➢ W.O.N. the accused’s right to bail was violated.
HELD:
➢ NO. It is clear from Section 13, Article III of the 1987 Constitution and Section 3, Rule 114 of the Revised Rules of Court, as amended, that before conviction bail is either a matter of right or of discretion. It is a matter of right when the offense charged is punishable by any penalty lower than reclusion perpetua. To that extent the right is absolute. If the offense charged is punishable by reclusion perpetua bail becomes a matter of discretion. It shall be denied if the evidence of guilt is strong. The court's discretion is limited to determining whether or not evidence of guilt is strong. But once it is determined that the evidence of guilt is not strong, bail also becomes a matter of right. If an accused who is charged with a crime punishable by reclusion perpetua is convicted by the trial court and sentenced to suffer such a penalty, bail is neither a matter of right on the part of the accused nor of discretion on the part of the court1.
RULING:
➢ WHEREFORE, judgment is hereby rendered:
1) In G.R. No. 90643, AFFIRMING the appealed Decision in Criminal Case No. 219 of Branch 55 of the Regional Trial Court, Fifth Judicial Region, at Irosin, Sorsogon, with the modification of the indemnity which is increased from P20,000.00 to P40,000.00; and
2) In G.R. No. 91155, DENYING, for lack of merit, the petition2.
1 People vs. Fortes, 223 SCRA 619, G.R. No. 90643, G.R. No. 91155 June 25, 1993 2 Ibid., p. 637
