People v. Follantes
REITERATIONFacts
The Antecedents: The appellant, Anacleto Follantes, was convicted of murder by the lower court and sentenced to the penalty of reclusion perpetua. Procedural History: Following his conviction, the appellant sought to perfect bail in the amount of P15,000, which had been authorized by the lower court for his provisional liberty, pending the final determination of his appeal. The Appeal: The appellant's petition to perfect bail pending appeal was brought before the Supreme Court for resolution.
Issue(s)
Whether an accused convicted of murder, and sentenced to reclusion perpetua, is entitled to bail pending appeal.
Ruling
The petition to perfect bail pending appeal is denied. Persons convicted of a crime punishable by death, such as murder, are not bailable as a matter of right. The right to bail before conviction exists only when the evidence of guilt is not strong. After conviction, the right to bail is not absolute and is generally not recognized, with exceptions provided by law, such as when the penalty imposed is not death and the appeal is pending, in which case it is a matter of judicial discretion.
Ratio Decidendi
On Whether an accused convicted of murder, and sentenced to reclusion perpetua, is entitled to bail pending appeal: The Court held that the appellant is not entitled to bail pending his appeal. The crime of murder is punishable by reclusion temporal in its maximum period to death, as provided by Article 248 of the Revised Penal Code. According to Article III, Section 1, Paragraph 16 of the Constitution, persons convicted of a crime punishable by death are not bailable. The constitutional guarantee of the right to bail before conviction is only applicable when the evidence of guilt is not strong. The Court further clarified that under Section 2 of Act No. 4178, while defendants are admitted to bail as a matter of right after judgment by a justice of the peace, in all non-capital cases after judgment by any other court, it is a matter of judicial discretion. However, since murder is a capital offense, the general rule that bail is not recognized after conviction applies, and the appellant's petition must be denied.
Main Doctrine
Persons convicted of murder, a crime punishable by reclusion perpetua to death, are not bailable as a matter of right. While the Constitution guarantees the right to bail before conviction unless the evidence of guilt is strong, after conviction, the right to bail is significantly curtailed and is generally not recognized, except in specific instances provided by law, such as when the penalty imposed is not death and the appeal is pending, in which case it becomes a matter of judicial discretion.