Trillanes v. Pimentel

ANTONIO TRILLANES IV v. HON. OSCAR PIMENTEL SR. (D)
G.R. No. 179817 June 27, 2008

FACTS:

• July 27, 2003, a group of more than 300 heavily armed soldiers led by junior officers of the Armed Forces of the Philippines (AFP) stormed into the Oakwood Premier Apartments in Makati City and publicly demanded the resignation of the President and key national officials.
• On the same day, President Gloria Macapagal Arroyo issued Proclamation No. 427 and General Order No. 4 declaring a state of rebellion and calling out the Armed Forces to suppress the rebellion. 
• Petitioner Antonio F. Trillanes IV was charged, along with his comrades, with coup d’etat defined under Article 134-A of the Revised Penal Code before the RTC of Makati.
• 4 years later, petitioner, who has remained in detention, threw his hat in the political arena and won a seat in the Senate with a 6-year term commencing at noon on June 30, 2007.
• Petitioner filed with the RTC, Makati City, Branch 148, an "Omnibus Motion for Leave of Court to be Allowed to Attend Senate Sessions and Related Requests".
• The trial court denied all the requests in the Omnibus Motion.

ISSUE:

• Whether or not membership in Congress exempt an accused from statutes and rules which apply to validly incarcerated persons in general

HELD:

• No, it is impractical to draw a line between convicted prisoners and pre-trial detainees for the purpose of maintaining jail security; and while pre-trial detainees do not forfeit their constitutional rights upon confinement, the fact of their detention makes their rights more limited than those of the public.
• When a person indicted for an offense is arrested, he is deemed placed under the custody of the law. He is placed in actual restraint of liberty in jail so that he may be bound to answer for the commission of the offense. He must be detained in jail during the pendency of the case against him, unless he is authorized by the court to be released on bail or on recognizance.
• Presumption of innocence does not carry with it the full enjoyment of civil and political rights.
• Allowing accused-appellant to attend congressional sessions and committee meetings for 5 days or more in a week will virtually make him a free man with all the privileges appurtenant to his position. Such an aberrant situation not only elevates accused-appellant’s status to that of a special class, it also would be a mockery of the purposes of the correction system.