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People Vs Donato (198 SCRA 130 Facts

Salas, who was charged with rebellion as an NPA member, filed a petition for writ of habeas corpus. During a conference, the parties agreed that Salas would withdraw his petition and remain in custody pending further investigation and trial. Based on this agreement, the Supreme Court dismissed the habeas corpus case. However, Salas later applied for and was granted bail by a trial court judge without hearing from the prosecution. The Supreme Court ruled that Salas waived his right to bail when he withdrew his habeas corpus petition per the agreement to remain in custody, and the trial court judge should not have granted bail.
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0% found this document useful (0 votes)
479 views1 page

People Vs Donato (198 SCRA 130 Facts

Salas, who was charged with rebellion as an NPA member, filed a petition for writ of habeas corpus. During a conference, the parties agreed that Salas would withdraw his petition and remain in custody pending further investigation and trial. Based on this agreement, the Supreme Court dismissed the habeas corpus case. However, Salas later applied for and was granted bail by a trial court judge without hearing from the prosecution. The Supreme Court ruled that Salas waived his right to bail when he withdrew his habeas corpus petition per the agreement to remain in custody, and the trial court judge should not have granted bail.
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People vs Donato (198 SCRA 130

FACTS:

Salas aka NPA’s “Ka Bilog” was arrested and was charged for rebellion. He was charged
together with the spouses Concepcion. Salas, together with his co-accused later filed a petition
for the Writ of Habeas Corpus. A conference was held thereafter to hear each party’s side. It was
later agreed upon by both parties that Salas will withdraw his petition for the WoHC and that he
will remain in custody for the continued investigation of the case and that he will face trial. The
SC then, basing on the stipulations of the parties, held to dismiss the habeas corpus case filed by
Salas. But later on, Salas filed to be admitted for bail and Judge Donato approved his application
for bail. Judge Donato did not bother hearing the side of the prosecution. The prosecution argued
that Salas is estopped from filing bail because he has waived his right to bail when he withdrew
his petition for habeas corpus as a sign of agreement that he will be held in custody.

ISSUE: Whether or not Salas can still validly file for bail.

HELD: The SC ruled that Salas did waive his right to bail when he withdrew his petition for the
issuance of the Writ of Habeas Corpus. The contention of the defense that Salas merely agreed to
be in custody and that the same does not constitute a waiver of his right to bail is not tenable. His
waiver to such right is justified by his act of withdrawing his petition for Writ of Habeas Corpus.

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