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URGENT PETITION FOR RELEASE OF PRISONERS DUE TO COVID-19 PANDEMIC v. PEOPLE

FACTS:

On April 6, 2020, the petitioners, who are prisoners and among the elderly, sick, and pregnant population of inmates, filed a petition before the Supreme Court seeking temporary release on humanitarian grounds due to the COVID-19 pandemic. They argued that their continued confinement poses a high risk of contracting the virus and violates their constitutional rights. They invoked the Court's power to exercise equity jurisdiction and requested either recognizance or bail. They also asked the Court to create a Prisoner Release Committee to study and implement the release of eligible prisoners to decongest jails. The respondents, represented by the Office of the Solicitor General, opposed the petitioners' plea for temporary release and the creation of a Prisoner Release Committee, arguing that the petitioners are members of the CPP-NPA-NDF who have committed heinous crimes. They also claimed that the government has adequate measures to address the threat of COVID-19 in jails and detention facilities. The respondents argued that the petitioners have other remedies available to them and that their release would pose a threat to public safety.

ISSUES:

  1. Whether or not the instant petition filed directly before this Court may be given due course.

  2. Whether or not the Nelson Mandela Rules are enforceable in Philippine courts.

  3. Whether or not petitioners may be given provisional liberty on the ground of equity.

  4. Whether or not the Court has the power to pass upon the State's prerogative of selecting appropriate police power measures in times of emergency.

RULING:

  1. The Supreme Court is a collegiate judicial body whose rulings and binding opinions are the results of its members' collective and majoritarian consensus. The Court unanimously treats the petition as the petitioners' applications for bail or recognizance, as well as their motions for other confinement arrangements relative to the alleged serious threats to their health and lives. However, the Court explains that it is not a trier of facts and does not have the authority to directly adjudicate factual questions presented for the first instance. The Court affirms that entitlement to bail is a question of fact that should be determined by the trial courts, in accordance with the rules governing the weight of evidence. Thus, the Court refers the petition to the respective trial courts where the criminal cases of the petitioners are pending and directs the trial courts to conduct necessary proceedings and resolve these incidents promptly.

PRINCIPLES:

  • The Supreme Court is a collegiate judicial body, and its rulings and opinions are the result of collective and majoritarian consensus.

  • The Supreme Court is not a trier of facts, and it is not the proper avenue or forum to ventilate factual questions, especially those presented for adjudication on the first instance.

  • Entitlement to bail is a question of fact, and the determination of bail applications is within the discretion of the trial courts, taking into account the weight of evidence.

  • The Court has the authority to treat a petition as an application for bail or recognizance if the petitioners are charged with offenses punishable by reclusion perpetua and the evidence of guilt is strong.

  • The Court has the power to refer a petition to the trial courts for necessary proceedings and prompt resolution.