People of the Philippines, petitioner, v. Dr. David A Sobrespeña, Sr.

, respondent
G.R. No. 204063
December 5, 2016

DOCTRINE: The determination of whether the evidence of guilt is strong is a matter of judicial discretion
which remains with the judge. The judge is under legal obligation to conduct a hearing, whether
summary or in the discretion of the court, to determine the existence of strong evidence or lack of it.

FACTS:
Respondents were charged for allegedly committing Estafa and Large Scale Illegal Recruitment. The RTC
ruled against the respondents, stating that evidence of guilt against them was strong. Thus, the
respondents’ petition for bail was denied.

However, the Court of Appeals reversed the ruling of the trial court and gave due course to the
respondents’ petition for bail. According to the appellate court, there is doubt as to whether there was a
strong evidence for the charge of estafa or large-scale illegal recruitment.

ISSUE: Whether or not the CA committed a serious reversible error in giving due course to the petition -
YES

HELD:
As provided in Sec. 13, Art. 3 of the 1987 Constitution and Sec. 7, Rule 114, of the Rules of Court, the
determination of whether the evidence of guilt is strong is a matter of judicial discretion which remains
with the judge. The judge is under legal obligation to conduct a hearing, whether summary or in the
discretion of the court, to determine the existence of strong evidence or lack of it. The court’s grant or
denial of bail must contain a summary of evidence of the prosecution which is the basis of the judge’s
conclusion whether the evidence is strong enough to indicate the guilt of the accused.

In a summary hearing, the Court does not sit to try the merits of the case. It is only a speedy and brief
method of receiving and considering the evidence of guilt as is practicable and consistent with the
purpose of determining the weight of evidence for the purposes of bail.

In this case, the RTC held a summary hearing and based on the summary of evidence, formulated a
conclusion denying the Petition to Bail. In the CA decision, the issue resolved was with the merits of the
case and not on the application for bail. The matters dealt with in the appellate court involved the
evaluation of evidence which was not within its jurisdiction to resolve in a Petition for Certiorari. The
findings of the trial court during the bail hearing were only a preliminary appraisal of the prosecution’s
evidence to determine whether the respondents are entitled to be release on bail.