G.R. No.

129670 February 1, 2000

Lavides vs. CA
FACTS:

Petitioner Lavides was arrested without warrant for child abuse under RA no. 7610. The parents of Lorelie who
are one of the complainants, reported to the police that their daughter, then 16 yrs. Old had been contacted by
petitioner at the latter’s hotel room in Quezon city. It was alleged in all separate 9 cases, petitioner had sexual
intercouses with the complainants. Lavides filed separate application for bail in those 9 cases. Trial court set the case for
arraignment and issued an order resolving petitioner’s Omnibus Motion which imposed 4 conditions to the accused. The
latter filed a motion to quash the info against him, suspend the arraigment and reduce the amounts of bail bonds. In
separate orders, RTC denied. The petitioner assailed in the Court of Appeals the RTC order of denying his motion to
quash and maintaining the conditions. CA invalidated the 1 st 2 conditions imposed for the grant of bail but the validity of
the condition making arraignment a prerequisite for the approval of petitioner’s bail bonds to be moot and academic.
ISSUES:
Whether the condition imposed by the court that the approval of petitioner’s bail bonds “shall be made only
after his arraignment”
HELD:
In cases where it is authorized, bail should be granted before arraignment, otherwise the accused may be
precluded from filing a motion to quash. For if the information is quashed and the case is dismissed, there would
then be no need for the arraignment of the accused. In the second place, the trial court could ensure the presence
of petitioner at the arraignment precisely by granting bail and ordering his presence at any stage of the proceedings,
such as arraignment. Under Rule 114, §2(b) of the Rules on Criminal Procedure, one of the conditions of bail is that
"the accused shall appear before the proper court whenever so required by the court or these Rules," while under
Rule 116, §1(b) the presence of the accused at the arraignment is required.
G.R. No. 128551 July 31, 2000 People v. Samolde, 376 SCRA 632
Facts:
Accused-appellant Ramil Samolde was charged, together with Armando Andres, the crime of murder. Both
accused pleaded not guilty in the arraignment. Samolde claimed that he was beaten up by the police. He
testified that during his detention, he was not allowed to be seen, lest visitors notice his swollen face. As regards
his counsel, he stated that, contrary to what was stated in his extrajudicial confession, his lawyer did not really
assist him. He was not informed of his constitutional rights when he executed his extrajudicial confession, and he
did so only after he had been subjected to some brutality by the police.
Issue:
Whether the extrajudicial confession of the accused-appellant admissible in evidence.
Held:
No. The extrajudicial confession of accused-appellant is not admissible in evidence, he was not informed of his
constitutional rights before his statement was taken.
Under Art. III, §12(1) of the Constitution, a suspect in custodial investigation must be given the following
warnings: “(1) He must be informed of his right to remain silent; (2) he must be warned that anything he says can
and will be used against him; and (3) he must be told that he has a right to counsel, and that if he is indigent, a
lawyer will be appointed to represent him. As the above quoted portion of the extrajudicial confession shows,
accused-appellant was given no more than a perfunctory recitation of his rights, signifying nothing more than a
feigned compliance with the constitutional requirements. This manner of giving warnings has been held to be
“merely ceremonial and inadequate to transmit meaningful information to the suspect

Naconvict ni guilty ang tawo kay may sufficient evidence beyond reasoanable doubt kag ang judical confession which is
the highest evidence so miski invalid ang extrajudical confession naconvict pa rin xa sg evidence kag sg judical confession.
G.R. No. 139599 February 23, 2000
ANICETO SABBUN MAGUDDATU and LAUREANA SABBUN MAGUDDATU
vs.
COURT OF APPEALS

FACTS:
Petitioners were charged with murder before the Regional Trial Court of Makati. They filed a motion to be admitted
to bail on the ground that the prosecution's evidence is not strong. After partial trial, the trial court issued an order
granting petitioners' motion for bail and fixing the amount at P30,000.00 each. Petitioners posted bail through
AFISCO Insurance Corporation. AFISCO Insurance Corporation filed a motion before the trial court praying for the
cancellation of petitioner's bail bond because of the latter's failure to renew the same upon its expiration. Trial court
convicted petitioners and the judgment of conviction was promulgated in absentia. Petitioners filed a Notice of
Appeal from the order of conviction for homicide with a motion to be granted provisional liberty under the same
bail bond pending appeal.2 Court of Appeals issued the resolution denying petitioners' application for bail and
ordering their arrest.
ISSUES:
1. Whether petitioners are entitled to bail as a matter of right or on the discretion of the trial court.
2. Assuming a matter of discretion, whether the trial court committed grave abuse of discretion in denying
bail.
HELD:
1. A matter of Discretion. Constitution guarantees the right to bail of all the accused except those
charged with offenses punishable by reclusion perpetua when the evidence of guilt is strong.
Sec. 5. Bail, when discretionary. — Upon conviction by the Regional Trial Court of an offense
not punishable by death, reclusion perpetua or life imprisonment, the court, on application,
may admit the accused to bail.

2. NO. Petitioners are not entitled to bail since they violated the conditions of their bail. Petitioners'
non-appearance during the promulgation of the trial court's decision despite due notice and
without justifiable reason, and their continued non-submission to the proper authorities as
ordered by the Court of Appeals, constitute violations of the conditions of their bail. Moreover, it
appears that petitioners failed to renew their expired bail bond with AFISCO Insurance
Corporation.
G.R. No. 130663 March 20, 2001
PEOPLE OF THE PHILIPPINES, appellee,
vs.
ANGELES STA. TERESA, appellant.

FACTS:
Regional Trial Court of Cabanatuan City finding Angeles Sta. Teresa guilty beyond reasonable doubt of raping his
12-year old daughter and imposing upon him the supreme penalty of death. When arraigned, appellant with the
assistance of his counsel de oficio4 pleaded "not guilty."5 But after the prosecution presented its witnesses medico-
legal officer, and the rape victim – appellant withdrew his plea of "not guilty" and changed it to a plea of "guilty." 6 He
said that he "had no intention to commit such act because he was drunk, and was not on his right mind. When
asked for comment by the trial court, appellant's counsel de oficio responded, "…the accused openly admits his
guilt, I am not anymore in a position to oppose the said formal offer of exhibits.” The trial court then admitted all the
documentary exhibits offered by the prosecution without any comment and/or objection from the defense counsel. It
granted the motion of appellant to change his plea to one of guilt. Thereafter, it re-read to the accused the complaint
filed against him, interpreted it and explained it in a language which he understood -- all these with the assistance of
his counsel de oficio. The trial court then called appellant to the witness stand. There, he testified how the rape
occurred. After testifying, he asked for pardon.
ISSUE:
Whether the court a quo gravely erred in not entering a plea of not guilty for the accused-appellant and in not
affording the latter the opportunity to adduce controverting evidence in blatant violation of his right to due process.
HELD:
YES. The sconstitutional standards impelled by due process have not been complied, thus, necessitating the
remand of this case for further proceedings.
Section 3, Rule 116 of the Revised Rules of Criminal Procedure, as follows:
SEC. 3. Plea of guilty to capital offense; reception of evidence. -- When the accused pleads guilty to a
capital offense, the court shall conduct a searching inquiry into the voluntariness and full comprehension of
the consequences of his plea and shall require the30.230.2 prosecution to prove his guilt and the precise
degree of culpability. The accused may present evidence in his behalf.
 We hold that the abbreviated and aborted presentation of the prosecution evidence and appellant's
improvident plea of guilty, with the scanty and lackluster performance of his counsel de oficio, are just too
exiguous to accept as being the standard constitutional due process at work enough to snuff out the life of a
human being. As exemplified in People v. Bermas:18
"x x x The right to counsel proceeds from the fundamental principle of due process which basically means that a
person must be heard before being condemned. The due process requirement is a part of a person's basic rights; it
is not a mere formality that may be dispensed with or performed perfunctorily.
 As a lawyer sworn to uphold justice and the law, he had the bounden duty to exert utmost efforts to defend
his client and protect his rights, no matter how guilty or evil he appears to be. This duty becomes more
compelling if his client is accused of a grave crime and is in danger of forfeiting his life if he is convicted.
G.R. No. 124097 June 17, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee,
vs.
CARLOS BONGHANOY, accused-appellant.

FACTS:
Baby Jane de Guzman y Bonghanoy, assisted by her mother, accuses Carlos Bonghanoy y
Agrabiador alias "Caloy" of the crime of rape. Upon his arraignment, accused-appellant pleaded not guilty. Caloy
denied the charge hurled against him, claiming that he had drinking spree with his friends. Accused-appellant
testified that he could not have raped his niece. In support of his testimony, Caloy presented one of his alleged
drinking partners Balvino Alingas. Alingas testified that he drank with Caloy from 5:00 p.m. until the time he left at
12:00 midnight, with the latter on the floor dead drunk. The trial court rendered a decision finding accused-appellant
guilty of the crime of rape.

ISSUE:
WHETHER THE LOWER COURT ERRED IN NOT GIVING CREDENCE TO THE TESTIMONY OF
DEFENSE'S WITNESSES THAT HE DID NOT COMMIT THE CRIME CHARGED.

HELD:

NO. Accused-appellant never mentioned Balvino Alingas as one of his drinking companions that fateful evening. In
contrast, the latter asserted that he was part of the drinking session. . If, indeed, Alingas was present during
accused-appellant's drinking spree, his presence would have been adverted to by accused-appellant. This all too
evident omission indicates Alingas' narration to be mere fabrication intended to get accused-appellant off the hook.
Accused-appellant's alibi, unsubstantiated as it is by clear and convincing evidence is negative and self-serving
evidence which deserves no weight in law. 7
G.R. No. 128280 April 4, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee,
vs.
ALICIA A. CHUA, accused-appellant.

FACTS:
Accused Alicia Chua has appealed from the decision of the Regional Trial Court, Manila finding her guilty
1

beyond reasonable doubt of illegal recruitment committed in large scale and eight (8) counts of estafa. On
November 8, 1993, the trial court arraigned the accused. She pleaded not guilty to each case. Trial ensued. The
13

cases were consolidated and tried jointly.

ISSUE:
Whether the accused was denied the constitutional right to compulsory process.
HELD:
NO. The 1973 and 1987 Constitutions expanded the right to compulsory process which now includes the right to
secure the production of evidence in one's behalf. B aaay analogy, U.S. vs. Ramirez which laid down the
28 29

requisites for compelling the attendance of witnesses, may be applied to this expanded concept. Thus, the movant
must show: (a) that the evidence is really material; (b) that he is not guilty of neglect in previously obtaining the
production of such evidence; (c) that the evidence will be available at the time desired; and (d) that no similar
evidence could be obtained.
In the case at bar, the trial court correctly denied appellant's motion for the production of the records which
were the basis in issuing the POEA Certification dated February 3, 1994, as the same would not in any way alter
30

the undisputed fact that appellant was not issued a license until then.31