BY THE PEOPLE | Quiboloy’s Precept of Surrender

Noel Lazaro 

In Christianity, surrendering means placing trust in the divine will. Proverbs say to lean on the Lord, not ourselves. But Apollo Carreon Quiboloy’s return after seven months in hiding brings questions. To whom did the pastor surrender? Was it an act of faith or fear? The debate runs deep.

On September 8, 2024, Secretary Benjamin Abalos Jr. announced Quiboloy's capture on social media, shocking a public still reeling from Alice Guo's apprehension. Quiboloy's defenders quickly reframed the narrative, insisting that the 74-year-old leader, facing a 74-page U.S. indictment for sex trafficking and cash smuggling, had willingly surrendered. Meanwhile, his lawyers directed pointed criticisms at the president’s inner circle.

Department of Justice Secretary Jesus Remulla later revealed that Quiboloy’s surrender followed intense pressure from authorities, including threats of a significant police operation led by General Nicolas Torre III. This blurring of lines between voluntary surrender and coercion prompts scrutiny from multiple viewpoints.

The legal framework surrounding surrender can be odd but uncomplicated. The Rules of Court defines “arrest” as the taking of a person into custody, whether through restraint or submission. Thus, whether we label Quiboloy's situation as an arrest or a surrender may be less crucial than it appears; either way, he is under arrest.

Law dean Israelito Torreon offers a nuanced critique, claiming we can't hold both views simultaneously. He states that the court only obtains jurisdiction over the accused through arrest or “voluntary appearance/surrender.” This suggests Quiboloy could only have surrendered. However, Miranda v. Tuliao (G.R. No. 158763, March 31, 2006) distinguishes between custody of the law and jurisdiction over the accused. The first necessitates arrest or voluntary surrender; the second entails arrest or voluntary appearance.

To simplify, custody of the law and jurisdiction over the accused can be seen as two distinct entities at a party—one might linger in the corner while the other is out on the dance floor. Voluntary surrender resembles checking into jail, while voluntary appearance is akin to showing up for a court date.

In People v. Quiboloy, Crim. Case No. R-QZN-24-04799-CR, a Quezon City court issued an arrest warrant against those accused of child sexual abuse. In his order dated September 9, 2024, Judge Noel Parel noted that Quiboloy and his co-accused had been “arrested.” While Quiboloy may not have voluntarily appeared before the court, it is undeniable that he was under arrest.

So why must someone who could “pass through walls” and “stop earthquakes” insist he voluntarily surrendered? The intent to establish a foundation for leniency is apparent. If this claim holds, it could significantly affect sentencing. The Revised Penal Code allows for reduced penalties for voluntary surrender, provided certain criteria are met: the offender must not have been arrested, the surrender must be to persons in authority, and it must be voluntary.

Following People v. Oco (G.R. Nos. 137370-71, September 29, 2003), the surrender must be “spontaneous,” indicating an “unconditional” intent to submit—either through admitting guilt or by sparing authorities the effort and cost of finding them. Luces v. People (G.R. No. 149492, January 20, 2003) emphasizes that “surrender presupposes repentance.” For example, in People v. Viernes (G.R. Nos. 136733-35, December 13, 2001), simply going to the police station to clear one’s name did not equate to surrender.

Given the imminent threat of arrest, marked by warrants from both the Senate and the court, along with a high-profile manhunt and a siege of his sprawling Davao City compound, one could argue that Quiboloy’s actions were driven more by necessity than genuine willingness to surrender. His dramatic descent from the mountains—rather than a climb from a bunker—aims to portray him as a protector of his flock from lawlessness. However, this narrative does little to mask the reality that he was cornered.

His “ultimate sacrifice” lacks the voluntary essence required; for months, he dangled the prospect of surrender only if guaranteed against extradition. Once in custody, his legal team criticized the breach of surrender terms, including the release of his mugshot and the press briefing that showcased him.

In People v. Garcia (G.R. No. 174479, June 17, 2008), the Supreme Court determined that the accused did not truly surrender after shooting the victim. He concealed himself for hours and engaged in negotiations before finally giving up surrounded by the police. Like Quiboloy, none of the factors that would qualify the surrender as voluntary were present. Both figures dropped anchor when the current became too strong.

Although Quiboloy’s surrender is legally ambiguous, it carries a heavy symbolism of invincibility. Perception is a powerful tool. He who commands "six million followers in about 200 countries" does not easily yield to 2,000 pursuers. The “owner of the universe” isn’t taken down; he is offered up.

If surrender is indeed a pathway to renewal and transformation, as Romans 12:1-2 teaches, then the journey toward accountability and meaningful reform remains a crucial hope for all involved.