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EDUARDO TOLENTINO RODRIGUEZ v. PRESIDING JUDGE OF RTC OF MANILA – BRANCH 17

FACTS:

The case involves a special civil action for certiorari and prohibition against the Orders of the Regional Trial Court of Manila that cancelled the bail of the petitioners and denied their motion for reconsideration. The case stems from a petition for extradition filed by the Government of the United States of America (US government) against the petitioners. The petitioners were arrested and applied for bail, which was initially granted by the trial court. However, the US government filed a motion for reconsideration, which was subsequently denied. Dissatisfied with the denial, the US government filed a petition for certiorari with the Supreme Court. The Supreme Court directed the trial court to resolve the matter of bail in accordance with a similar case. Consequently, the trial court cancelled the cash bond of the petitioners and issued a warrant of arrest against them. The petitioners filed a motion for reconsideration, which was denied. Now, the petitioners file the present petition, asserting that the cancellation of their bail without prior notice and hearing constituted a grave abuse of discretion. They also argue that certain special circumstances should be considered as exceptions to the no-bail rule in extradition cases.

ISSUES:

  1. Is prior notice and hearing required before bail is cancelled in an extradition case?

  2. What constitutes a "special circumstance" to be exempt from the no-bail rule in extradition cases?

RULING:

  1. Prior notice and hearing are not required before bail is cancelled in an extradition case. The issuance of a warrant of arrest ex parte against an extraditee is not a violation of the due process clause. The purpose of the arrest warrant would be defeated if prior notice and hearing were required as it could give warning to the extraditee and encourage them to flee.

  2. The Court did not specify what constitutes a "special circumstance" to be exempt from the no-bail rule in extradition cases.

PRINCIPLES:

  • Prior notice and hearing are not required before bail is cancelled in an extradition case.

  • The purpose of an arrest warrant in an extradition case would be defeated if prior notice and hearing were required.

  • The Court did not provide a clear definition or guidance on what constitutes a "special circumstance" to be exempt from the no-bail rule in extradition cases.