View full case

PEOPLE v. MANUEL ESCOBAR

FACTS:

In this case, respondent Manuel Escobar filed a petition for bail (First Bail Petition) after being charged as a co-conspirator in the kidnapping for ransom of Mary Grace Cheng-Rosagas and two other victims. The Regional Trial Court and the Court of Appeals denied the First Bail Petition. However, a subsequent development in the case prompted Escobar to file a second petition for bail (Second Bail Petition). The Regional Trial Court denied the Second Bail Petition on the ground of res judicata, but the Court of Appeals granted it in a decision dated March 24, 2014. Escobar was suspected of conspiring with others to abduct the victims at gunpoint and detain them in an undisclosed location. The ransom was eventually paid and the victims were released after more than 12 hours of captivity. One of the accused, Cancio Cubillas, implicated Escobar as an adviser for the alleged group leader. Escobar was arrested on February 14, 2008, and his First Bail Petition was filed on June 3, 2008. The First Bail Petition was denied for lack of merit.

The case involves a kidnapping incident where several individuals were accused. One of the accused, Manuel Escobar, filed a petition for bail which was denied by the trial court. The denial was affirmed by the Court of Appeals, and Escobar's motion for reconsideration was also denied. Meanwhile, one of the co-accused, Rolando Fajardo, also filed a petition for bail and was initially denied. However, the trial court later reversed its decision and granted Fajardo's bail application due to a lack of evidence of his participation in the kidnapping. Escobar, seeing this development, filed another petition for bail based on the same ground, but it was denied by the trial court, citing the principle of res judicata. Escobar's motion for reconsideration was also denied. He then appealed to the Court of Appeals via Rule 65, arguing that the trial court committed grave abuse of discretion. The Court of Appeals granted Escobar's petition and ordered the trial court to determine the appropriate bail for his provisional liberty. The prosecution filed a petition for review before the Supreme Court, arguing that the doctrine of res judicata should be respected.

The case involves the petition for bail filed by the accused, Rolando Escobar. Escobar argued that res judicata did not apply in his case and that there was no strong evidence of his guilt. He claimed that his alleged participation in the crime was based on unreliable speculations of the state witness, Cubillas, who admitted to lying during Escobar's bail hearings. Escobar believed that it was in the interest of justice and fairness to re-open the matter of bail and grant him the same privilege as his co-accused who had already been granted bail. The City Jail Warden, Randel H. Latoza, reviewed Escobar's case in compliance with the court's program to decongest holding jails. In his manifestation to the court, City Jail Warden Latoza confirmed that there was no temporary restraining order against the Regional Trial Court's order fixing Escobar's provisional liberty at P300,000.00. He also acknowledged the Court of Appeals' decision granting Escobar the right to bail and noted that Escobar had already posted the bail as ordered by the trial court.

ISSUES:

  1. Whether Manuel Escobar's second petition for bail is barred by res judicata.

  2. Whether or not res judicata applies in criminal proceedings.

  3. Whether or not the denial of the second bail petition gives rise to res judicata.

  4. Whether or not the March 8, 2011 Court of Appeals Decision, denying the petitioner's first bail petition, had the effect of res judicata.

  5. Whether or not the Regional Trial Court should have taken cognizance of the petitioner's second bail petition.

  6. Whether or not the Court of Appeals can reverse its decision, despite denying the first bail petition.

  7. Whether or not the petitioner's second bail petition should have been granted.

  8. Whether or not the petitioner can be provisionally released if he has paid the surety bond.

RULING:

  1. The Court of Appeals correctly ruled that Escobar's Second Bail Petition was not barred by res judicata.

  2. Res judicata does not apply in criminal proceedings as it is a principle in civil law. Although certain provisions of the Rules of Civil Procedure may be applied in criminal cases, Rule 39 of the Rules of Civil Procedure, which includes res judicata, is excluded from the application in criminal cases.

  3. The denial of the second bail petition does not give rise to res judicata. An interlocutory order denying a bail application is not considered a final judgment on the merits of the case. Res judicata applies only to final judgments, and an interlocutory order settles only some incidental, subsidiary, or collateral matter in an action. Therefore, there is no res judicata that bars the filing of a second bail petition.

  4. The March 8, 2011 Court of Appeals Decision, denying the petitioner's first bail petition, did not have the effect of res judicata since it was an interlocutory order and the kidnapping case itself has not attained finality.

  5. The Regional Trial Court should have taken cognizance of the petitioner's second bail petition and weighed the strength of the evidence of guilt against him.

  6. The Court of Appeals can still reverse its decision, notwithstanding the denial of the first bail petition on March 8, 2011.

  7. The petitioner's second bail petition should have been given due course and should not have been denied on the technical ground of res judicata.

  8. The petitioner may be provisionally released if he has paid the surety bond.

PRINCIPLES:

  • The right to bail is cognate to the fundamental right to be presumed innocent. It is accorded to a person in custody who may be allowed provisional liberty upon the filing of security to guarantee his or her appearance before any court, as required under specified conditions.

  • Bail may be a matter of right or judicial discretion. The accused has the right to bail if the offense charged is not punishable by death, reclusion perpetua, or life imprisonment. However, if the accused is charged with an offense punishable by death, reclusion perpetua, or life imprisonment and the evidence of guilt is not strong, then the accused's prayer for bail is subject to the discretion of the trial court.

  • The doctrine of res judicata bars the re-litigation of the same claim between the parties (claim preclusion) or the re-litigation of the same issue on a different claim between the same parties (issue preclusion). It exists as an obvious rule of reason, justice, fairness, expediency, practical necessity, and public tranquility.

  • Section 47 of Rule 39 of the Revised Rules of Civil Procedure states that a judgment or final order rendered by a court may be conclusive between the parties and their successors in interest by title subsequent to the commencement of the action or special proceeding, litigating for the same thing and under the same title and in the same capacity.

  • Res judicata is a doctrine of civil law and does not apply in criminal proceedings.

  • An interlocutory order does not give rise to res judicata as it is not a final judgment on the merits of the case. Res judicata only applies to final judgments.

  • Res judicata requires the concurrence of certain elements: (a) the judgment sought to bar the new action must be final; (b) the decision must have been rendered by a court having jurisdiction over the parties and the subject matter; (c) the disposition of the case must be a judgment on the merits; and (d) there must be identity of parties, subject matter, and causes of action between the first and second actions.

  • A hearing for bail is summary in nature and does not try the merits of the case. Its purpose is to determine the weight of the evidence for purposes of bail.

  • Rules of procedure should not be interpreted to disadvantage a party and deprive them of fundamental rights and liberties.

  • A judgment or order may be modified if executing it in its present form is impossible or unjust in view of intervening facts or circumstances.

  • Appellate courts may correct errors of judgment if blind adherence to the doctrine of immutability of final judgments would sacrifice justice for technicality.

  • All persons, except those charged with offenses punishable by reclusion perpetua when evidence of guilt is strong, shall be bailable before conviction.

  • The grant of bail does not prevent the trier of facts from making a final assessment of the evidence after full trial on the merits.