Defensor-Santiago vs Vasquez

217 SCRA 633

Facts: An information was filed against petitioner for violation of the Anti-Graft and Corrupt Practices Act. Subsequently, a warrant of arrest was issued against her. Petitioner filed an "Urgent Ex-parte Motion for Acceptance of Cash Bail Bond for and in behalf of her since petitioner was hospitalized after a vehicular accident.

Issue: WON an accused confined in a hospital be deemed in the custody of the law and is thus, entitled to bail.

Held: Yes. If accused clearly communicates his/her submission to the court.

We find and so hold that petitioner is deemed to have voluntarily submitted herself to the jurisdiction of respondent court upon the filing of her aforequoted "Urgent Ex-parte Motion for Acceptance of Cash Bail Bond for and in behalf of Dr. Miriam Defensor-Santiago" wherein she expressly sought leave "that she be considered as having placed herself under the jurisdiction of (the Sandiganbayan) for purposes of the required trial and other proceedings," and categorically prayed "that the bail bond she is posting in the amount of P15,000.00 be duly accepted" and that by said motion "she be considered as having placed herself under the custody" of said court. Petitioner cannot now be heard to claim otherwise for, by her own representations, she is effectively estopped from asserting the contrary after she had earlier recognized the jurisdiction of the court and caused it to exercise that jurisdiction over the aforestated pleadings she filed therein.

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