Title
Marcos vs. Sandiganbayan
Case
G.R. No. 115132-34
Decision Date
Aug 9, 1995
Imelda Marcos sought to travel abroad for medical treatment, but the Sandiganbayan denied her motion, citing insufficient proof of necessity. The Supreme Court upheld the decision, emphasizing the need to balance her rights with the State's interest in enforcing judgments.

Case Digest (G.R. No. L-45966)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • Petitioner: Imelda R. Marcos, former First Lady and widow of former President Ferdinand E. Marcos, is the accused in several criminal cases involving violations of the Anti Graft and Corrupt Practices Act (R.A. No. 3019).
    • Criminal Convictions:
      • In Criminal Case Nos. 17450 and 17453, petitioner was found guilty by the First Division of the Sandiganbayan for violating section 3(g) of the said law.
      • She was sentenced in each case to imprisonment for an indeterminate period (minimum of 9 years and 1 day to a maximum of 12 years and 10 days) along with perpetual disqualification from public office.
    • Pending Petitions:
      • A motion for reconsideration was filed by petitioner in these cases and was pending before the Sandiganbayan.
  • Filing of Motions for Leave to Travel Abroad
    • Initial Motion:
      • On December 24, 1993, petitioner filed a "Motion for Leave to Travel Abroad" in connection with her need to seek diagnostic tests and treatment in the People’s Republic of China for a “serious and life threatening medical condition.”
      • The motion was denied by the Sandiganbayan on procedural grounds, including failure to notify the prosecution and the proximity of the requested travel date.
    • Subsequent Filing in a Separate Case:
      • On December 29, 1993, petitioner filed an “Urgent Ex-Parte Motion for Permission to Travel Abroad” in Criminal Case No. 18742 for diagnostic tests and treatment in China, based on medical reports and tests by her attending physician, Dr. Roberto V. Anastacio, and other doctors from Makati Medical Center.
    • Additional Motions in Other Cases:
      • On January 4, 1994, petitioner submitted another “Motion for Leave to Travel Abroad” in criminal cases 17450 and 17453 for treatment in the United States and Europe “if necessary” for conditions including hypertensive heart disease, uncontrolled angina pectoris, and anterior myocardial infarction.
      • It was argued that the necessary diagnostic tests were not available in the Philippines.
  • Judicial Proceedings and Assistance of Medical Experts
    • Inquiry and Referral to Experts:
      • Presiding Justice Francis E. Garchitorena of the Sandiganbayan contacted Dr. Gregorio B. Patacsil of the Philippine Heart Center to obtain “expert opinion on coronary medicine.”
      • The inquiry included several specific questions regarding the urgency and necessity of the petitioner’s medical condition, the availability of necessary tests in the Philippines, and the adequacy of local medical expertise.
    • Subsequent Supplement Filing:
      • On January 17, 1994, petitioner filed a “Supplement to the Motion for Leave Abroad” with additional supporting documents, including international letters offering diagnostic and treatment facilities.
    • Expert Committee Report:
      • On January 20, 1994, the Sandiganbayan received a report from a committee of cardiologists (comprising Dr. Ramon F. Abarquez, Jr., Dr. Homobono B. Calleja, and Dr. Romeo A. Divinagracia).
      • The report, which was contrary to petitioner’s physicians’ opinions, cast doubt on the necessity and urgency of petitioner's travel abroad.
    • Hearings and Testimonies:
      • Hearings on January 7, January 26, February 11, and other dates featured testimony from petitioner’s attending physician, other expert witnesses, and representatives of the committee.
      • The court allowed petitioner’s counsel to supplement the record with additional questions for the committee.
    • Resolution on the Motions
      • On February 18, 1994, the Sandiganbayan denied petitioner’s motions to travel abroad, stating that the imperative necessity for a trip abroad for diagnostic tests had not been established.
      • A subsequent motion for reconsideration and additional motions involving recognizance and clinical summaries were also filed.
  • Subsequent Developments and Additional Motions
    • Motion for Leave to Travel Regarding Glaucoma
      • Petitioner later filed another motion to travel abroad, this time seeking treatment for a difficult type of glaucoma, supported by a detailed medical certificate from Dr. Manuel B. Agulto.
      • The motion requested evaluation by an internationally renowned eye specialist, Dr. Richard J. Simmons, and proposed the formation of a joint panel of eye specialists.
  • Allegations Against the Court's Conduct
    • Petitioner’s Allegations of Abuse of Discretion
      • Petitioner contended that the Sandiganbayan arbitrarily disregarded and misinterpreted the testimony and findings of her attending physicians.
      • It was alleged that the court’s conduct was unorthodox, including:
        • Initiating independent inquiries by contacting third parties.
ii. Actively participating in witness examination and presentation of its own witnesses. iii. Deciding on the matter based on evidence obtained through its own inquiry rather than solely on the parties’ submissions.
  • Constitutional and Due Process Claims
    • Petitioner argued that her constitutional rights to life, health, and liberty were compromised.
    • It claimed that the court’s actions infringed upon her rights to personal liberty, due process, and the right to travel, especially in light of her pending criminal cases.

Issues:

  • Abuse of Discretion
    • Whether the Sandiganbayan, by expanding its fact-finding through independent solicitation of expert opinions, acted with grave abuse of discretion in denying petitioner’s request to travel abroad.
  • Procedural Fairness and Due Process
    • Whether the manner in which the court conducted the trial—actively questioning witnesses, forming an expert committee, and seeking additional information—violated the due process rights of the petitioner.
    • Whether petitioner was prejudiced by not timely objecting to the court’s unorthodox trial conduct.
  • Evidentiary Basis for Denial
    • Whether the available evidence, including conflicting medical reports and test results from petitioner’s own physicians compared to the expert committee, substantiated the conclusion that there was no imperative necessity for travel abroad for diagnosis and treatment.
  • Balancing Individual Rights Against Judicial Authority
    • Whether the court properly balanced the petitioner’s constitutional right to health, life, and liberty against the state's interest in ensuring her presence during pending criminal proceedings.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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