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    Facts:: G.R. No. 214300, July 26, 2017 People of The Philippines, Petitioner vs. MANUEL ESCOBAR, Respondent

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    Man2x Salomon
    Manuel Escobar was suspected of conspiring in a kidnapping for ransom case. He filed a first petition for bail that was denied. A subsequent development in his case led him to file a second bail petition, which the trial court denied based on res judicata. The Court of Appeals overturned this decision. The Supreme Court ruled that Escobar's second bail petition was not barred by res judicata, as that doctrine does not apply to criminal cases under the Rules of Criminal Procedure. Even if it did apply, there was no final judgment on the merits of the case from the denial of the first bail petition.

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    Facts:: G.R. No. 214300, July 26, 2017 People of The Philippines, Petitioner vs. MANUEL ESCOBAR, Respondent

    Uploaded by

    Man2x Salomon
    564 views1 page
    Manuel Escobar was suspected of conspiring in a kidnapping for ransom case. He filed a first petition for bail that was denied. A subsequent development in his case led him to file a second bail petition, which the trial court denied based on res judicata. The Court of Appeals overturned this decision. The Supreme Court ruled that Escobar's second bail petition was not barred by res judicata, as that doctrine does not apply to criminal cases under the Rules of Criminal Procedure. Even if it did apply, there was no final judgment on the merits of the case from the denial of the first bail petition.

    Original Description:

    People v. Escobar case digest; law files; remedial law

    Original Title

    People v. Escobar

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    Manuel Escobar was suspected of conspiring in a kidnapping for ransom case. He filed a first petition for bail that was denied. A subsequent development in his case led him to file a second bail petition, which the trial court denied based on res judicata. The Court of Appeals overturned this decision. The Supreme Court ruled that Escobar's second bail petition was not barred by res judicata, as that doctrine does not apply to criminal cases under the Rules of Criminal Procedure. Even if it did apply, there was no final judgment on the merits of the case from the denial of the first bail petition.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    564 views1 page

    Facts:: G.R. No. 214300, July 26, 2017 People of The Philippines, Petitioner vs. MANUEL ESCOBAR, Respondent

    Uploaded by

    Man2x Salomon
    Manuel Escobar was suspected of conspiring in a kidnapping for ransom case. He filed a first petition for bail that was denied. A subsequent development in his case led him to file a second bail petition, which the trial court denied based on res judicata. The Court of Appeals overturned this decision. The Supreme Court ruled that Escobar's second bail petition was not barred by res judicata, as that doctrine does not apply to criminal cases under the Rules of Criminal Procedure. Even if it did apply, there was no final judgment on the merits of the case from the denial of the first bail petition.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 1

    G.R. No.

    214300, July 26, 2017

    PEOPLE OF THE PHILIPPINES, Petitioner


    vs. MANUEL ESCOBAR, Respondent

    FACTS:
    Escobar was suspected of conspiring in the kidnap for ransom of Mary
    Grace, daughter of Filipino-Chinese businessman Robert, and 2 other
    victims. Robert was the owner of Uratex Foam, Philippines, a manufacturing
    company of foams and mattresses.
    An Amended Information was filed before the Regional Trial Court
    charging Escobar as a co-conspirator in the kidnapping for ransom.
    Escobar was arrested. H filed a petition for bail (First Bail Petition), which
    was denied by the Regional Trial Courtand by the Court of Appeals. A subsequent
    development in the accused's case compelled him to file a second petition for bail
    (Second Bail Petition). The Regional Trial Court denied this on the ground of res
    judicata. The Court of Appeals overturned the Regional Trial Court Order and
    granted the Second Bail Petition.

    ISSUE:
    Whether or not Escobar' s Second Bail Petition is barred by res judicata.

    RATIO DECIDENDI:
    No. Escobar’s Second Bail Petition is not covered by res judicata as this
    doctrine is not recognized in criminal proceedings.
    Rule 124, Section 18 of the Rules of Criminal Procedure states:
    Section 18. Application of certain rules in civil procedure to criminal cases. - The
    provisions of Rules 42, 44 to 46 and 48 to 56 relating to procedure in the Court of
    Appeals and in the Supreme Court in original and appealed civil cases shall be
    applied to criminal cases insofar as they are applicable and not inconsistent with
    the provisions of this Rule.
    Indeed, while certain provisions of the Rules of Civil Procedure may be
    applied in criminal cases, Rule 39 of the Rules of Civil Procedure is excluded from
    the enumeration under Rule 124 of the Rules of Criminal Procedure.
    Even assuming that this case allows for res judicata as applied in civil cases,
    Escobar’s Second Bail Petition cannot be barred as there is no final judgment on
    the merits.
    A decision denying a petition for bail settles only a collateral matter-whether
    accused is entitled to provisional liberty-and is not a final judgment on accused's
    guilt or innocence.

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