Case Digest (G.R. No. 213847)
Facts:
Juan Ponce Enrile v. People of the Philippines, G.R. No. 213455, August 11, 2015, the Supreme Court En Banc, Brion, J., writing for the Court.On June 5, 2014 the Office of the Ombudsman filed an Information for plunder (Republic Act No. 7080) against Juan Ponce Enrile (then a senator) and several co‑accused, alleging that from 2004 to 2010 Enrile and others conspired to amass Php172,834,500.00 in ill‑gotten wealth through a combination or series of overt acts involving the diversion of Priority Development Assistance Fund (PDAF) projects to NGOs linked to Janet Lim Napoles. The Information charged, among other things, receipt of kickbacks from Napoles or her representatives in connection with PDAF projects.
Before the Sandiganbayan (Third Division) Enrile filed (a) an urgent omnibus motion (including a motion to dismiss and, ad cautelam, for bail) and (b) a motion for bill of particulars and for deferment of arraignment. On July 3, 2014 the Sandiganbayan denied the motions and ordered issuance of arrest warrants; on July 11, 2014 the Sandiganbayan denied Enrile’s motion for a bill of particulars and his oral motion for reconsideration in a Minute Resolution, proceeded with arraignment after determining Enrile fit, and entered a plea of not guilty on his behalf when he did not plead.
Enrile filed a petition for certiorari in the Supreme Court challenging the Sandiganbayan’s July 11, 2014 denials as grave abuse of discretion amounting to lack or excess of jurisdiction and asserting violation of his constitutional right to be informed of the nature and cause of the accusation. He sought a TRO staying pre‑trial and further proceedings, expedited resolution, and setting of oral arguments. The People (represented by the Ombudsman/Special Prosecutor) opposed, arguing the Information alleged the ultimate facts and that many requested particulars were evidentiary and not required in an Information.
The Court En Banc resolved the petition: it partially granted relief, held that some particulars sought were material (not merely evidentiary), set aside the Sandiganbayan’s July 11, 2014 resolutions denying a bill of particulars and motion for reconsideration, and direct...(Subscriber-Only)
Issues:
- Did the Sandiganbayan commit grave abuse of discretion amounting to lack or excess of jurisdiction in denying petitioner Enrile’s motion for a bill of particulars and his motion for reconsideration?
- If grave abuse is shown, what particulars in Enrile’s motion for a bill of particulars are material (i.e., must the prosecution supply them) and which are evidentia...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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