Case Digest (G.R. No. 247611) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In The People of the Philippines vs. Ramon “Bong” Revilla, Jr., Richard A. Cambe, and Janet Lim Napoles (G.R. No. 247611), resolved by the Supreme Court Second Division on January 13, 2021, accused-appellant Janet Lim Napoles sought provisional release from the Correctional Institution for Women pending her appeal for conviction of plunder under Republic Act No. 7080, as amended. On December 7, 2018, the Sandiganbayan Special First Division convicted Napoles and her business associate Richard A. Cambe of amassing at least ₱50,000,000.00 in ill-gotten wealth through misuse of Senator Revilla’s Priority Development Assistance Fund and sentenced them to reclusion perpetua with perpetual absolute disqualification from public office. Napoles filed an urgent motion for recognizance/bail or house arrest on humanitarian grounds, invoking her alleged risk of contracting COVID-19 due to diabetes, the Supreme Court’s rulings in De La Rama v. People’s Court and Enrile v. Sandiganbayan, Offi Case Digest (G.R. No. 247611) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents
- On December 7, 2018, the Sandiganbayan Special First Division convicted Richard A. Cambe and Janet Lim Napoles of Plunder (Criminal Case No. SB-14-CRM-0240) for misusing Senator Bong Revilla Jr.’s PDAF and sentenced them to reclusion perpetua.
- Napoles appealed her conviction to the Supreme Court (G.R. No. 247611) and remained detained at the Correctional Institution for Women (CIW) pending resolution.
- Napoles’ Motion
- Napoles filed an Urgent Motion for Recognizance/Bail or House Arrest for Humanitarian Reason Due to COVID-19, alleging she has Type 2 Diabetes Mellitus and hypertension, placing her at high risk inside the prison.
- She invoked (a) this Court’s decisions in De La Rama v. People and Enrile v. Sandiganbayan (special medical-health precedents), (b) OCA Circular No. 91-2020 (detention decongestion guidelines), and (c) the Nelson Mandela Rules and international calls for temporary release of PDLs during the pandemic.
Issues:
- Whether the Constitution and the Rules of Court allow bail pending appeal of a capital-offense conviction.
- Whether Napoles may be provisionally released on humanitarian grounds due to COVID-19 risk.
- Whether the Nelson Mandela Rules and international calls for PDL release suffice to grant bail post-conviction.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)