Case Digest (G.R. No. 224162)
Facts:
Janet Lim Napoles v. Sandiganbayan (Third Division), G.R. No. 224162, August 13, 2018, Supreme Court En Banc, Reyes, Jr., J., writing for the Court.Petitioner Janet Lim Napoles sought reconsideration (filed December 20, 2017) of this Court’s Decision dated November 7, 2017, which had dismissed her petition and affirmed the Sandiganbayan Resolutions dated October 16, 2015 and March 2, 2016 denying her application for bail in SB-14-CRM-0238. The November 7, 2017 Decision concluded that the Sandiganbayan did not commit grave abuse of discretion amounting to lack or excess of jurisdiction in denying bail.
In her motion for reconsideration Napoles relied on the Court’s ruling in Macapagal-Arroyo v. People (G.R. No. 220598, July 19, 2016), arguing that that decision — which reversed the Sandiganbayan’s denial of the demurrer to evidence in the plunder case against former President Gloria Macapagal-Arroyo because the prosecution failed to specify the identity of the main plunderer — should apply to her and compel relief.
The Supreme Court denied Napoles’ motion. The Court distinguished the posture and standards of a demurrer to evidence (a trial-on-the-merits device that tests whether the prosecution has proven guilt beyond reasonable doubt, and if successful is equivalent to acquittal) from a petition for bail (a summary hearing confined to determining whether there is evident proof of guilt sufficient to justify continued detention). Citing its prior decisions and the Rules of Court, the Court concluded that the Macapagal-Arroyo ruling — which addressed insufficiency of proof at the demur...(Subscriber-Only)
Issues:
- Does the ruling in Macapagal-Arroyo v. People apply to petitioner Napoles’ case and require reversal of the Sandiganbayan’s denial of bail?
- Did the Sandiganbayan commit grave abuse of discretion in denying Napoles’ appli...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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