Case Digest (G.R. No. 218232) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On June 5, 2014, the Office of the Ombudsman filed before the Sandiganbayan Criminal Case No. SB-14-CRM-0240 an Information charging Senator Ramon “Bong” B. Revilla, Jr. (Revilla), his Chief of Staff Richard A. Cambe (Cambe), and businesswoman Janet Lim Napoles (Napoles) with plunder under Section 2 of Republic Act No. 7080, as amended. It was alleged that from 2006 to 2010 Revilla’s Priority Development Assistance Fund (PDAF) allocations, totalling some ₱517 million, were diverted to ghost projects implemented by NGOs controlled by Napoles, in exchange for kickbacks that purportedly amassed ₱224,512,500.00. After arraignment (Revilla entered no plea; Cambe and Napoles pleaded not guilty), the Sandiganbayan issued warrants of arrest on June 19, 2014. Revilla and Cambe voluntarily surrendered and, by separate Resolutions of June 20, 2014, were committed to the Philippine National Police–Criminal Investigation and Detection Group (PNP-CIDG) Custodial Center in Camp Crame. Revi Case Digest (G.R. No. 218232) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Case Background
- Five petitions consolidated before the Supreme Court En Banc: G.R. Nos. 218232 (Revilla), 218235 (Cambe), 218266 (Napoles), 218903 (People’s petition on detention transfer), and 219162 (preliminary attachment).
- Originated from an Information dated 5 June 2014 in Sandiganbayan Criminal Case No. SB-14-CRM-0240 charging public officers with Plunder under RA 7080 as amended.
- Information and Arraignment
- Petitioners charged with conspiracy to amass ill-gotten wealth of at least ₱224,512,500 through kickbacks on PDAF projects.
- Upon arraignment, Napoles and Cambe pleaded not guilty; Revilla refused to plead and was entered not guilty by operation of law.
- Arrest, Detention, and Bail Applications
- Warrants of arrest issued 19 June 2014; Revilla and Cambe voluntarily surrendered and were detained at the PNP Custodial Center, Camp Crame.
- Bail petitions filed: Revilla (20 June 2014), Cambe (23 June 2014), Napoles (25 June 2014, jointly with co-accused Lim and De Asis).
- Bail Hearings and Evidence
- Prosecution presented nine witnesses from COA, DBM, NBI, AMLC, and whistleblowers (Luy, SuAas, Sula, Baltazar).
- Evidence summarized: six SAROs (Table A) and additional receipts (Table B) totaling ₱224,512,500 in alleged kickbacks; AMLC report showed NGO accounts under JLN control.
- Defense witness Atty. Pagui testified that signatures on PDAF documents were not genuine; other defense exhibits excluded for lack of sponsorship.
- Sandiganbayan Resolutions
- 1 December 2014 – Denied bail for Revilla, Cambe, and Napoles upon finding “strong evidence” of Plunder.
- 26 March 2015 – Denied motions for reconsideration of bail denials.
- 4 September 2014 & 20 May 2015 – Denied prosecution’s motion to transfer Revilla and Cambe from PNP to BJMP facility.
- 5 February 2015 & 28 May 2015 – Granted ex parte writ of preliminary attachment against Revilla’s assets; denied his motion for reconsideration.
Issues:
- G.R. No. 218232 (Revilla)
- Whether Sandiganbayan gravely abused discretion in denying Revilla’s bail application despite allegedly insufficient evidence of guilt.
- G.R. No. 218235 (Cambe)
- Whether Sandiganbayan erred by applying an incorrect test (“proof evident” vs. constitutional “strong evidence”) to deny bail.
- Whether reliance on “totality of evidence” (a writ of amparo standard) was improper.
- Whether conclusions were based on mere presumptions and inferences.
- G.R. No. 218266 (Napoles)
- Whether bail denial was arbitrary given alleged lack of strong evidence of conspiracy and credible documentary and testimonial proof.
- G.R. No. 218903 (Ombudsman’s petition)
- Whether Sandiganbayan abused discretion by refusing to transfer Revilla and Cambe to a BJMP-operated jail.
- Whether detention at PNP Custodial Center afforded “special treatment” contrary to law.
- G.R. No. 219162 (Revilla)
- Whether issuing the ex parte writ of preliminary attachment was premature and violated presumption of innocence.
- Whether factual and legal prerequisites for the writ were lacking.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)