Dela Rama vs The Peoples Court

1946; Feria, J.:

Nature of Action:

Petition for Certiorari (2 nd Petition)

Facts: The first petition for certiorari on the decision of the Peoples Court denying the
petition for bail was remanded to the said court because of a supplemental motion raising
new facts, supported by medical certificates, which arise only during its pendency before
the SC.
SC held in the first petition: Unless allowance of bail is forbidden by law in the particular
case, the illness of the prisoner, independently of the merits of the case, is a
circumstance, and the humanity of the law makes it a consideration which should,
regardless of the charge and the stage of the proceeding, influence the court to ex ercise its
discretion to admit the prisoner to bail.
Before hearing by the Peoples Court, Motion asking Dela Rama to be confined and treated
in a hospital outside the Bilibid Prison. Special Prosecutor opposed on the ground is in
effect an attempt to obtain by indirection what the accused has failed to obtain directly, i. e.,
his provisional release.
Peoples Court ordered Dela Ramas confinement in Quezon Institute with an order that the
Medical Director submit a report every 15 days. He was found actually suffering
tuberculosis and pharyngitis, they "have seen similar cases, later progressing into
advance stages when the treatment and medicine are no longer of any avail;" and
recommended to continue his stay in the institute.
Petition for bail was filed that he may be confined in his own house and treated by a
specialist, since he could not afford to pay the expenses which he stay in the Quezon
Institute would entail. Petition was denied and the court ordered his continued
confinement.
Issue: Whether the People's Court has acted with grave abuse of discretion in denying the
petitioner's petition for bail.
Held: Yes. Considering the report of the Medical Director; also the previous petition for
bail which was denied because Dela Rama was suffering from quiescent and not active
tuberculosis and the implied purpose of sending him to the Institute was to verify whether
it is an active tuberculosis to decide on his petition for bail; and the application of cases
against Pio Duran and Benigno Aquino, in which the said defendants were released on bail
on the ground that they were ill and their continued confinement in New Bilibid Prison
would be injurious to their health or endanger their life.
The order of the People's Court denying the petition for bail is set aside, and said
court is ordered to render within a reasonable time a new decision in conformity
with the said doctrine applied by the same court in the cases above mentioned.