Case Digest (G.R. No. 213847) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 213847, decided July 12, 2016, petitioner Juan Ponce Enrile, then a sitting Senator, was charged by the Office of the Ombudsman with the crime of plunder under Republic Act No. 7080 before the Sandiganbayan (Third Division). On June 5, 2014, the Sandiganbayan issued an information, and on June 10 Enrile filed an omnibus motion praying that he be allowed to post bail if probable cause were found. On July 3 the court denied this omnibus motion as premature and ordered his arrest. Enrile voluntarily surrendered and, on July 4, sought detention at the Philippine National Police General Hospital citing his advanced age and frail health. On July 7 he filed a Motion to Fix Bail, invoking his age, health, and non-flight-risk as mitigating circumstances. The Ombudsman opposed both motions. On July 9 the Sandiganbayan authorized his medical detention but did not fix bail; on July 14 it denied the bail motion for prematurity, and on August 8 it denied his motion for reconsidera Case Digest (G.R. No. 213847) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Underlying criminal case
- On June 5, 2014, former Senate President Juan Ponce Enrile was charged with plunder (Republic Act No. 7080) before the Sandiganbayan (Third Division) under Case No. SB-14-CRM-0238.
- A warrant of arrest issued July 3, 2014; Enrile voluntarily surrendered and was detained at the PNP General Hospital due to claimed health issues.
- Motions before the Sandiganbayan
- June 10, 2014 – Enrile filed an Omnibus Motion for Bail, citing advanced age and frail health; submitted medical certificates.
- July 7, 2014 – He filed a Motion to Fix Bail, arguing age and voluntary surrender as mitigating, and low flight risk.
- July 9, 2014 – Sandiganbayan granted hospital detention but denied the bail motion as premature; People of the Philippines opposed both motions.
- Supreme Court proceedings
- August 18, 2015 – En Banc granted Enrile’s petition for certiorari, annulled Sandiganbayan resolutions of July 14 and August 8, 2014, set bail at ₱1,000,000, and ordered immediate release.
- People filed a Motion for Reconsideration, challenging the grant of bail on constitutional and procedural grounds.
- July 12, 2016 – En Banc denied the motion for reconsideration, affirming the August 2015 decision.
Issues:
- Constitutional and statutory basis for bail
- Whether a person charged with a crime punishable by reclusion perpetua can be granted bail based on health and low flight risk.
- Whether the evidence of guilt was “strong” (thus barring bail under Art. III, Sec. 13, 1987 Constitution).
- Procedural due process
- Whether the People were afforded a fair opportunity to contest Enrile’s health‐based grounds for bail.
- Whether the Supreme Court improperly relied on grounds not raised or litigated before the Sandiganbayan.
- Equal protection
- Whether Enrile’s release constituted undue favoritism or preferential treatment inconsistent with the Equal Protection Clause.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)