Santiago vs Vasquez

Facts: An information was filed against petitioner with the Sandiganbayan for alleged
violation of Section 3(e), Republic Act No. 3019 otherwise known as the Anti-Graft and
Corrupt Practices Act. An order of arrest against petitioner was issued by the
Sandiganbayan with bail for release fixed at Php. 15,000. In response, petitioner filed a
motion for acceptance of cash bail bond and a prayer to recall the warrant of arrest issued
against her on the ground that she cannot appear nor speak in the court due to the
injuries she sustained as a result of vehicular accident. Acting on the motion of the
petitioner, the Sandiganbayan issued a resolution authorizing the petitioner to post
cash bond for her provisional liberty. Later on, the Ombudsman filed a manifestation with
the Sandiganbayan that petitioner had not sustained injuries when she came and left
unaided in the former’s office. This was contrary to petitioner’s previous averment on why
she posted bail in the first place. Her arraignment was set, but petitioner asked for
the cancellation of her bail bond and that she be allowed provisional release on
recognizance. The Sandiganbayan deferred it and issued a hold departure order against
petitioner in connection to the latter’s announcement in the media that she would be
leaving for the U.S. to accept a fellowship in Harvard. In the instant motion she submitted
before the Supreme Court, petitioner argues that her right to travel is impaired.

Issue: Whether or Not the hold departure order issued by the Sandiganbayan against
the petitioner is in violation of the latter’s right to travel?

Held:No. The hold departure order is but an exercise of a respondent court's inherent
power to preserve and maintain the effectiveness of its jurisdiction over the case and
person of the accused. Article III, Section 6 of the 1987 Constitution should by no means
be construed as delimiting the inherent power of the Courts to use all means necessary to
carry their orders into effect in criminal cases pending before them. When by law
jurisdiction is conferred on a Court or judicial officer, all auxiliary writs, processes and
other means necessary to carry it into effect may be employed by such Court or officer.
Courts have the power to prohibit a person admitted to bail an opportunity to leave the
Philippines. This is a necessary consequence of the nature and function of a bail bond.
Under the obligations assumed by petitioner in her bail bond, she holds herself amenable
at all times to the orders and processes of the court.