MANOTOC VS CA

Case Digest (G.R. No. L-62100)

Facts:
 Petitioner Ricardo L. Manotoc, Jr. requested permission to leave the country while facing criminal
charges and provisionally released on bail.
 The court denied his request, citing the condition imposed on the bail bond to make the accused
available at all times whenever the court requires his presence.
 The purpose of bail is to relieve the accused of imprisonment while ensuring their appearance before
the court.
 The custody of the accused is transferred to the sureties, who have the right to prevent the principal
from leaving the state.
 Petitioner failed to show the urgency of his travel, the duration thereof, and the consent of his
surety.

Issue:
 Can a person admitted to bail be prohibited from leaving the Philippines?

Ruling:
 Yes, a person admitted to bail can be prohibited from leaving the Philippines.

Ratio:
 The court held that a person admitted to bail can be prohibited from leaving the Philippines as a
necessary consequence of the nature and function of a bail bond.
 The purpose of bail is to relieve the accused of imprisonment while ensuring their appearance before
the court.
 The custody of the accused is transferred to the sureties, who have the right to prevent the principal
from leaving the state.
 The court rejected petitioner's reliance on a previous ruling that liberty under bail transcends
territorial boundaries, as the circumstances of the present case were different.
 The court found that petitioner failed to show the urgency of his travel, the duration thereof, and the
consent of his surety.
 Therefore, the court concluded that there was no abuse of judicial discretion in denying petitioner's
motion to leave the country.
 The court also noted that the constitutional right to travel is not absolute and can be impaired upon
lawful order of the court.
 In this case, the order of the trial court releasing petitioner on bail constituted a lawful order.
 The court dismissed the petition for review, upholding the decision of the appellate court.
MANOTOC VS CA

Case Summary (G.R. No. L-62100)

Background of the Case

 Petitioner: Ricardo L. Manotoc, Jr.
 Requested permission to leave the country while facing criminal charges and provisionally released
on bail.
 Court denied his request, citing the condition imposed on the bail bond.

Purpose of Bail
 Bail is meant to relieve the accused of imprisonment while ensuring their appearance before the
court.
 The court has the inherent right to prevent the principal from leaving the state.
 This right is recognized by the sureties who have authority over the person of the principal.

Previous Ruling on Liberty under Bail

 Petitioner relied on a previous ruling that liberty under bail transcends territorial boundaries.
 However, the court found that the circumstances of the present case were different.

Factors Considered in Denying the Request

 Petitioner failed to show the urgency of his travel.
 Petitioner failed to provide information on the duration of his travel.
 Petitioner failed to provide evidence of the consent of his surety.

No Abuse of Judicial Discretion

 The court found no abuse of judicial discretion in denying petitioner's motion to leave the country.
MANOTOC VS CA
1.) What was the reason for denying Ricardo L. Manotoc, Jr.'s request to leave the country?

The court denied his request because the condition imposed on the bail bond required his presence
in court at all times.

2.) Can a person admitted to bail be prohibited from leaving the Philippines?

Yes, a person admitted to bail can be prohibited from leaving the Philippines as a necessary
consequence of the nature and function of a bail bond.

3.) What is the purpose of bail?

The purpose of bail is to relieve the accused of imprisonment while ensuring their appearance before
the court.

4.) Who has the right to prevent the principal from leaving the state in a bail bond?

The sureties, to whom the custody of the accused is transferred, have the right to prevent the
principal from leaving the state.

5.) What did the court say about the previous ruling on the territorial boundaries of liberty
under bail?

The court rejected petitioner's reliance on a previous ruling, stating that the circumstances of the
present case were different.

6.) What factors did the court consider in determining whether to grant permission for
Ricardo L. Manotoc, Jr. to leave the country?

The court considered the urgency of his travel, the duration thereof, and the consent of his surety.

7.) Was there an abuse of judicial discretion in denying Ricardo L. Manotoc, Jr.'s motion to
leave the country?

No, the court concluded that there was no abuse of judicial discretion in denying his motion.

8.) What did the court say about the order releasing Ricardo L. Manotoc, Jr. on bail?

The court held that the order releasing him on bail constituted a lawful order under the
constitutional provision on the liberty of abode and travel.

9.) What was the outcome of the petition for review?

The petition for review was dismissed.

10.) What case is this jurisprudence based on?

This jurisprudence is based on the case of Manotoc, Jr. v. Court of Appeals.