Case Digest (G.R. No. L-45262)
Facts:
Jessica Lucila G. Reyes v. The Honorable Sandiganbayan Third Division and the People of the Philippines, G.R. No. 243411, August 19, 2020, the Supreme Court First Division, Reyes, J. Jr., writing for the Court.
Petitioner Jessica Lucila G. Reyes, formerly Chief of Staff to Senator Juan Ponce Enrile, was charged in an Information filed by the Office of the Ombudsman with plunder (and related corrupt acts) for allegedly conspiring with Senator Enrile, Janet Lim Napoles, and others to divert P172,834,500.00 in PDAF funds to fictitious "ghost" projects and to receive kickbacks. The charges arose from events between 2004 and 2010; the Ombudsman and the Sandiganbayan previously found probable cause against Reyes.
Petitioner sought provisional bail (bail ad cautelam). She filed a motion for bail on May 30, 2017. The Sandiganbayan, Third Division denied the motion in a Resolution dated June 28, 2018. Petitioner filed a motion for reconsideration and a supplemental motion for reconsideration; the Sandiganbayan denied those in a Resolution dated December 7, 2018. The June 28 Resolution was penned by Associate Justice Bernelito R. Fernandez (with two concurring members); the December 7 Resolution was penned by Associate Justice Amparo M. Cabotaje-Tang (with concurrences and one dissenting member at the Sandiganbayan level).
Between 2014 and 2018 this case produced several interlocutory rulings and related Supreme Court decisions. In Reyes v. Hon. Ombudsman (783 Phil. 304 (2016)) this Court upheld probable cause based on whistleblower and documentary evidence. The Court had earlier ordered the provisional release of co-accused Enrile in Enrile v. Sandiganbayan (767 Phil. 147 (2015)) on health grounds, and denied bail to Napoles in Napoles v. Sandiganbayan (G.R. No. 224162, Nov. 7, 2017), finding strong evidence of conspiracy and plunder. After the Sandiganbayan denied Reyes’s bail motions, Reyes filed the present Petition for Certiorari under Rule 65, alleging grave abuse of discretion ...(Subscriber-Only)
Issues:
- Did the Sandiganbayan commit grave abuse of discretion by delaying disposition of petitioner’s bail application and motions for reconsideration in violation of Section 6 of Presidential Decree No. 1606 and Part III, Section 10(a) of A.M. No. 15-06-10-SC?
- Did the Sandiganbayan commit grave abuse of discretion by adopting wholesale the Court’s findings in Napoles v. Sandiganbayan when resolving petitioner’s bail application (i.e., by taking judicial notice of another case’s record or treating that interlocutory determination as binding)?
- Did the Sandiganbayan commit grave abuse of discretion in concluding that the prosecution presented “strong evidence” of petitioner’s guilt and in denying her bail (specifically, were the testimonies of Ruby T...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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