Case Digest (G.R. No. 247611)
Facts:
The People of the Philippines v. Ramon "Bong" Revilla, Jr., Richard A. Cambe, and Janet Lim Napoles, G.R. No. 247611, January 13, 2021, the Supreme Court Second Division, Lopez, J., writing for the Court.The case arises from the Sandiganbayan Special First Division's Decision of December 7, 2018 in Criminal Case No. SB-14-CRM-0240, which convicted Richard A. Cambe and Janet Lim Napoles of plunder and sentenced them to reclusion perpetua; Senator Ramon "Bong" Revilla, Jr. was acquitted. After conviction, both Cambe and Napoles separately appealed to the Supreme Court; Napoles remained detained at the Correctional Institution for Women (CIW) pending resolution of her appeal.
While the appeal was pending, Janet Lim Napoles filed an Urgent Motion for Recognizance/Bail or House Arrest for Humanitarian Reason Due to COVID-19 before this Court, arguing that she was at heightened risk of contracting COVID-19 because she suffers from diabetes and hypertension. Napoles invoked this Court’s earlier humanitarian-release jurisprudence in De La Rama v. People's Court and Enrile v. Sandiganbayan, the Office of the Court Administrator’s OCA Circular No. 91-2020, and the United Nations' Nelson Mandela Rules, as well as the global practice of temporary release to decongest jails during the pandemic.
The Sandiganbayan had earlier denied Napoles’ bail application during summary hearing on the ground that the evidence of guilt was strong; the trial court later convicted her, finding the elements of plunder satisfied (including that the ill-gotten amount met the P50,000,000 threshold). Napoles submitted an unaut...(Pro-only)
Issues:
- Whether the Constitution and the Rules of Court allow an accused to post bail pending appeal after conviction for a capital offense.
- Whether Janet Lim Napoles may be provisionally released on humanitarian grounds because she is at risk of contracting COVID-19.
- Whether the Nelson Mandela Rules or international/state practice in response to COVID-19 provide a sufficient legal basis to grant bail...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)