G.R. No. 258841 - Juan Ponce Enrile vs. Sandiganbayan and People

On June 5, 2014, the Office of the Ombudsman filed an Information for Plunder against Juan Ponce Enrile, Jessica Lucila Reyes, Janet Lim Napoles, Ronald John Lim, and John Raymund de Asis before the Sandiganbayan.
The Information alleged that from around 2004 to 2010, Enrile (then a Philippine Senator) and Reyes (Chief of Staff of Enrile’s Office), both public officers, conspired with Napoles and others to amass ill-gotten wealth amounting to at least PHP 172,834,500.00 through a series of overt criminal acts involving kickbacks related to Enrile’s Priority Development Assistance Fund (PDAF) projects, which were purportedly fictitious.

Enrile filed a Motion for Bill of Particulars before the Sandiganbayan, which was denied.
Enrile then filed a Rule 65 Petition for Certiorari with the Supreme Court (G.R. No. 213455), seeking to annul the denial.
On August 11, 2015, the Supreme Court partially granted the petition and directed the prosecution to submit a Bill of Particulars specifying certain details about the overt acts, amounts of kickbacks, projects involved, and receiving parties. The Court clarified that other requests for particulars were denied.

The prosecution submitted its Bill of Particulars on May 16, 2016.
The Sandiganbayan conducted pre-trial conferences; Enrile filed several motions and manifestions arguing that the pre-trial orders should include the Bill of Particulars and limit prosecution’s evidence to those particulars.
The Sandiganbayan denied these motions in resolutions dated December 3, 2019; May 29, 2021; and June 9, 2021, stating that:

Separate pre-trial orders for multiple accused are not prohibited;
The pre-trial order need only define the central issue—whether Enrile was guilty of plunder; and
The prosecution is not limited to presenting evidence only on matters stated in the Bill of Particulars since it is not a complete listing of evidentiary evidence.

Enrile filed a Motion for Reconsideration of the June 9, 2021 Resolution, which the Sandiganbayan denied on July 12, 2021 reiterating that the motions contained proposals and objections without specific prayer and that the pre-trial order sufficiently defined the issues.

On the first day of trial, the prosecution announced that Atty. Ryan Medrano, a member of the Ombudsman’s field investigation team, would testify regarding non-implementation of projects funded by Enrile’s PDAF.
Enrile filed a Petition for Prohibition before the Supreme Court dated March 1, 2022, praying to enjoin the Sandiganbayan from acting on the case and to dismiss the criminal case, basing his arguments on:

The need to limit prosecution’s evidence to the Information and Bill of Particulars;
Sandiganbayan’s alleged disregard of the Bill of Particulars and related Supreme Court Decision;
That the pre-trial order improperly broadens the issues and fails to protect him from trial by surprise;
Alleged violation of his right to speedy trial and due process; and
That prohibition is the appropriate remedy.

The People raised procedural defenses, arguing that the Petition was filed out of time and lacked verified proof of service and that Enrile had other adequate remedies such as objections during trial and appeal. They asserted that the Bill of Particulars is not a limitation on the evidence and that the Sandiganbayan did not act with grave abuse of discretion.
Enrile opposed these points, contending the Petition was timely because the orders assailed were interlocutory, and that the available remedies were illusory given the Sandiganbayan’s consistent refusals.

Whether the Petition for Prohibition is procedurally defective.
Whether the Bill of Particulars should be incorporated in the Pre-Trial Order.
Whether the prosecution’s evidence should be limited only to matters stated in the Bill of Particulars.
Whether the Main Case should be dismissed on the grounds of violation of Enrile’s constitutional rights due to the Sandiganbayan’s actions.