Title
Enrile vs. Sandiganbayan, 3rd Division
Case
G.R. No. 213847
Decision Date
Jul 12, 2016
A 91-year-old former senator sought bail due to advanced age and frail health; the Supreme Court granted release, citing humanitarian grounds and low flight risk, despite charges of plunder punishable by life imprisonment.

Case Digest (G.R. No. 213847)

Facts:

Juan Ponce Enrile v. Sandiganbayan (Third Division), and People of the Philippines, G.R. No. 213847, July 12, 2016, Supreme Court En Banc, Bersamin, J., writing for the Court.

Petitioner Juan Ponce Enrile was charged with plunder (punishable by reclusion perpetua) before the Sandiganbayan (Third Division) on June 5, 2014. After issuance of the warrant of arrest, Enrile filed several pleadings: an Omnibus Motion (June 10, 2014), a Motion for Detention at the PNP General Hospital (July 4, 2014), and a Motion to Fix Bail (July 7, 2014). The Office of the Special Prosecutor filed a Consolidated Opposition to these motions. The Sandiganbayan on July 3, 2014 denied the Omnibus Motion as premature and ordered arrest; on July 9, 2014 it allowed hospital detention at the PNP General Hospital for medical examination; and on July 14, 2014 it denied the Motion to Fix Bail as premature. A subsequent Sandiganbayan resolution of August 8, 2014 denied reconsideration.

The Sandiganbayan had solicited medical opinions from physicians at the Philippine General Hospital (PGH); medical certificates and the testimony of PGH Director Dr. Jose C. Gonzales describing multiple, serious geriatric conditions were placed in the record. Enrile’s petitions to the Sandiganbayan and his annexes made his advanced age and frail health part of the record; the prosecution opposed these submissions in the Sandiganbayan.

Enrile petitioned the Supreme Court for certiorari to annul the Sandiganbayan resolutions. On August 18, 2015 the Court (En Banc) granted the petition for certiorari, annulled and set aside the Sandiganbayan resolutions of July 14 and August 8, 2014, ordered Enrile’s provisional release upon posting a P1,000,000 cash bond, and directed his immediate release unless detained for some other lawful cause. The People (through the Office of the Special Prosecutor) filed a Motion for R...(Subscriber-Only)

Issues:

  • Were the People denied due process or a reasonable opportunity to contest the factual basis (Enrile’s age and health) relied upon by the Court in granting provisional bail?
  • Did the Court err as a matter of law in granting bail to an accused charged with an offense punishable by reclusion perpetua (plunder) absent a prior Sandiganbayan determination that evidence of guilt is strong?
  • Did the grant of bail violate the People’s rights to due process and equal protection by giving...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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