Case Digest (G.R. No. 154953)
Facts:
Petitioner Janet Lim Napoles filed on December 20, 2017 a Motion for Reconsideration of this Court’s Decision dated November 7, 2017 dismissing her petition and affirming the Sandiganbayan Resolutions dated October 16, 2015 and March 2, 2016 in SB-14-CRM-0238 that denied her application for bail in the plunder case against her. In the lower court, the Sandiganbayan ruled that there was no grave abuse of discretion in refusing to grant bail, finding a great presumption of guilt from the evidence presented. Napoles then invoked the ruling in Macapagal-Arroyo v. People (promulgated on July 19, 2016), where the Court reversed the Sandiganbayan’s denial of a demurrer to evidence in the plunder case of former President Gloria Macapagal-Arroyo on the ground that the prosecution failed to prove beyond reasonable doubt the identity of the main plunderer. Napoles argued that this doctrine should extend to her bail proceeding.Issues:
- Should the ruling in Macapagal-Arroyo v. People, wh
Case Digest (G.R. No. 154953)
Facts:
- Procedural Posture
- On October 16, 2015 and March 2, 2016, the Sandiganbayan (Third Division) in SB-14-CRM-0238 denied petitioner Janet Lim Napoles’s application for bail.
- Napoles filed a petition for certiorari, prohibition, and mandamus before the Supreme Court, which on November 7, 2017 dismissed the petition and affirmed the Sandiganbayan’s resolutions for lack of grave abuse of discretion.
- Motion for Reconsideration and Invoked Authority
- On December 20, 2017, Napoles moved for reconsideration of the Supreme Court’s November 7, 2017 Decision.
- Napoles invoked the Supreme Court’s July 19, 2016 ruling in Macapagal-Arroyo v. People (G.R. No. 220598), which reversed the Sandiganbayan’s denial of a demurrer to evidence in former President Macapagal-Arroyo’s plunder case for failure to specify the principal plunderer.
Issues:
- Whether the ruling in Macapagal-Arroyo v. People—which dealt with the sufficiency of evidence in a demurrer to evidence—applies to Napoles’s petition for bail.
- Whether the Sandiganbayan gravely abused its discretion in denying Napoles’s bail application, warranting reversal by the Supreme Court.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)