**Facts:**
Ricardo C. Silverio was charged on October 14, 1985, with the violation of Section 20 (4) of the Revised Securities Act in the Regional Trial Court (RTC) of Cebu City, under Criminal Case No. CBU-6304. After posting bail for provisional liberty, Silverio encountered judicial proceedings that led to the controversial Supreme Court decision. On January 26, 1988, the People of the Philippines filed an Urgent ex-parte Motion to cancel Silverio’s passport and issue a hold-departure Order against him, due to multiple unauthorized overseas travels, causing arraignment and hearing delays. Despite Silverio’s opposition, the RTC issued an order on April 4, 1988, granting the motion based on Silverio’s repeated absences, which hindered legal proceedings. Silverio’s Motion for Reconsideration was denied on July 28, 1988. His subsequent Certiorari Petition to the Court of Appeals was dismissed on January 31, 1990, leading to this Supreme Court Petition for Review.
**Issues:**
1. Whether the RTC committed grave abuse of discretion in canceling Silverio’s passport and issuing a hold-departure order.
2. Whether the right to travel can be impaired by court orders based on reasons other than “interest of national security, public safety, or public health”.
**Court’s Decision:**
The Supreme Court affirmed the judgment of the lower courts, finding no reversible error. It ruled that:
1. The RTC’s orders were based on Silverio’s repeated failures to appear for arraignment, not on erroneous facts. These actions showed a disregard for court proceedings, justifying the travel restrictions.
2. The right to travel can be lawfully restricted by court orders beyond the grounds of national security, public safety, or public health, especially in cases where the accused has broken bail conditions. The 1987 Constitution does not limit the court’s inherent power to enforce its orders in criminal cases, including imposing travel restrictions on the accused.
**Doctrine:**
– The inherent power of Courts to enforce their orders in criminal cases includes imposing travel restrictions on accused individuals who have violated bail conditions, without being limited to the grounds specified for impairing the right to travel in the 1987 Philippine Constitution.
**Class Notes:**
– **Violation of Bail Conditions:** Accused individuals who fail to appear as required by the court may face restrictions on their right to travel as part of bail condition violations.
– **Right to Travel:** The right to travel can be restricted by courts as a means to ensure the accused’s availability for judicial processes, not purely on constitutional grounds of national security, public safety, or public health.
– **Judicial Power:** Courts possess inherent authority to use all means necessary to carry out their jurisdiction over criminal cases, including restraining the movement of accused individuals.
**Historical Background:**
This case reflects the judiciary’s approach to balancing individual liberties against the necessity of ensuring compliance with judicial proceedings. It highlights the evolution of the Philippine Constitution’s provisions on the right to travel and liberty of abode, from unrestricted judicial discretion to impose limitations to a more defined framework under the 1987 Constitution. However, it also affirms the enduring principle that judicial orders in criminal proceedings necessitate a broader interpretation of restrictions on personal freedoms to uphold the rule of law and public interest.
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