Facts:

• Petitioner Janet Lim Napoles filed a motion for reconsideration on December 20, 2017.
• The motion challenged the Court's Decision dated November 7, 2017.
• The case revolves around Napoles' application for bail, which the Sandiganbayan denied in its Resolutions dated October 16, 2015, and March 2, 2016.
• Napoles argued that the ruling in "Macapagal-Arroyo v. People" (July 19, 2016) should apply to her case.
• In the Macapagal-Arroyo case, the Sandiganbayan's denial of the demurrer to evidence in a plunder case against former President Gloria Macapagal-Arroyo was reversed due to the prosecution's failure to identify the main plunderer.
• Napoles contended that this precedent should influence her case.
• The Court found her argument unmeritorious and upheld the Sandiganbayan's denial of her bail application, citing no grave abuse of discretion amounting to lack or excess of jurisdiction.

Issue:

• (Unlock)

Ruling:

1. The Court ruled that the ruling in "Macapagal-Arroyo v. People" is not applicable to Napoles' case.
2. The Court upheld the Sandiganbayan's denial of Nap...(Unlock)

Ratio:

• The Court explained that a demurrer to evidence, as in the Macapagal-Arroyo case, involves challenging the sufficiency of the prosecution's entire evidence to establish the guilt of the accused beyond reasonable doubt.
• This is distinct from a hearing for a petition for bail, which is a preliminary determination of whether there is evident proof that the accused is guilty of the offense charged.
• The standard of proof in a bail hearing is less stringent than that required for a demurrer to evidence.
• The denial of the demurrer to evidence in the Macapagal-Arroyo case was based on the prosecution's failure to prove beyond reasonable doubt that former President GMA was the mastermind of the cons...continue reading