Case Digest (G.R. No. 213847)
Facts:
Juan Ponce Enrile v. Sandiganbayan (Third Division), G.R. No. 213847, August 18, 2015, Supreme Court En Banc, Bersamin, J., writing for the Court.The petitioner, Senator Juan Ponce Enrile, was charged by the Office of the Ombudsman with plunder before the Sandiganbayan (Third Division) on June 5, 2014. After the prosecution filed a consolidated opposition, Enrile filed an Omnibus Motion (June 10, 2014) and a Supplemental Opposition (June 16, 2014) requesting, among other reliefs, that he be allowed to post bail should probable cause be found.
On July 3, 2014 the Sandiganbayan denied the Omnibus Motion as premature and issued a warrant of arrest; Enrile voluntarily surrendered the same day and was confined at the PNP General Hospital following medical examination. On July 7, 2014 Enrile filed a Motion for Detention at the PNP General Hospital and a Motion to Fix Bail, which the Sandiganbayan heard on July 8, 2014. Enrile argued bail should be allowed because the prosecution had not shown strong evidence of guilt, the maximum penalty for him would be reclusion temporal (due to alleged mitigating circumstances), and he was not a flight risk given his age and medical condition.
By resolution dated July 14, 2014 the Sandiganbayan denied the Motion to Fix Bail as premature, stating that a bail hearing could only proceed after the prosecution presented evidence and the court determined whether “evidence of guilt is not strong.” The Sandiganbayan issued a second resolution on August 8, 2014 denying Enrile’s motion for reconsideration. (Separately, the Sandiganbayan had, in July 2014, allowed Enrile to remain at the PNP General Hospital for medical examination; that order was not the subject of the petition.)
Enrile petitioned the Supreme Court by petition for certiorari, alleging grave abuse of discretion amounting to lack or excess of jurisdiction in the Sandiganbayan’s denial of bail. The prosecution (Ombudsman) opposed, arguing entitlement to bail turns on the imposable penalty and, where the penalty is reclusion perpetua, a mandatory he...(Subscriber-Only)
Issues:
- Did the Sandiganbayan commit grave abuse of discretion amounting to lack or excess of jurisdiction in denying petitioner Juan Ponce Enrile’s Motion to Fix Bail?
- Was petitioner entitled to bail as a matter of right prior to conviction despite being charged with plunder (an offense punishable by reclusion perpetua) or was the exception under Article III, Section 13 applicable?
- Could humanitarian/medical considerations justify the grant of bail before a full determination on...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)