Title
Serapio vs. Sandiganbayan
Case
G.R. No. 148468
Decision Date
Jan 28, 2003
Edward Serapio, a trustee of a Muslim youth foundation, was accused of conspiring with President Estrada in plunder involving P4 billion in ill-gotten wealth. The Supreme Court ruled the charges defective, lacking evidence of Serapio's intent or direct involvement, granting him habeas corpus and ordering his release.

Case Digest (G.R. No. 148468)
Expanded Legal Reasoning Model

Facts:

  • Role of Petitioner and the Foundation
    • Edward S. Serapio was a member of the Board of Trustees and Legal Counsel of the non-stock, non-profit Erap Muslim Youth Foundation, established February 2000 to fund Muslim students and educators.
    • In April 2000, Governor Luis “Chavit” Singson donated ₱200 million to the Foundation via his assistant. Serapio received and turned over the funds to the Foundation’s treasurer, who deposited them in Equitable-PCI Bank.
  • Ombudsman Complaints and Preliminary Investigation
    • In late 2000, Singson publicly accused President Joseph E. Estrada and associates (including Serapio) of tolerating illegal jueteng. Three criminal complaints were filed with the Ombudsman (Nos. 0-00-1754, 0-00-1755, 0-00-1757).
    • Serapio filed a counter-affidavit (Feb 21, 2001). On April 4, 2001, after a joint resolution of preliminary investigation, the Ombudsman found probable cause for plunder and filed Information with the Sandiganbayan.
  • Filing of Information, Arrest and Detention
    • On April 18, 2001, the Ombudsman filed an amended Information in Sandiganbayan Criminal Case No. 26558, charging Estrada and co-accused (including Serapio) with plunder (ill-gotten wealth of ₱4.097 billion), specifying four predicate acts (paragraphs a–d). No bail was recommended.
    • The Sandiganbayan, on April 25, 2001, found probable cause and issued arrest warrants. Serapio surrendered that night and has been detained at Camp Crame.
  • Bail Petitions and Motions
    • Serapio filed an Urgent Petition for Bail (Apr 27, 2001). Co-accused filed similar motions. The Sandiganbayan initially set but repeatedly postponed bail hearings due to multiple motions: omnibus motions to hold proceedings in abeyance; motions for early arraignment; motion for joint bail hearing with other accused; motions for reconsideration; and motion to quash the Information.
    • On June 26, 2001, Serapio moved to quash the Information. The Sandiganbayan linked resolution of these incidents to the scheduling of his bail hearing and arraignment, eventually arraigning him on July 10, 2001, where a plea of not guilty was entered for him.
  • Supreme Court Petitions
    • G.R. No. 148468 (June 29, 2001): Petition for Certiorari and Habeas Corpus challenging Sandiganbayan’s orders (joint bail/trial hearing; denial of bail hearing).
    • G.R. No. 148769 (July 20, 2001): Certiorari petition assailing denial of motion to quash.
    • G.R. No. 149116 (Aug 9, 2001): Certiorari petition assailing denial of omnibus motion and its reconsideration.

Issues:

  • Arraignment and Bail Hearing
    • Is arraignment a prerequisite to the conduct of bail hearings?
    • Must Serapio wait for arraignment before seeking bail?
  • Motion to Quash vs. Bail Petition
    • Can Serapio file a motion to quash the Information while his bail petition is pending?
    • Does a motion to quash conflict with his right to seek bail?
  • Joint Bail and Trial Hearings
    • Is joint hearing of Serapio’s bail petition with other accused and with the merits trial mandatory?
    • Did the Sandiganbayan abuse its discretion by ordering such joint hearings?
  • Prosecution Evidence and Waiver
    • Did the prosecution waive its right to present evidence in opposition to bail?
    • Is the evidence against Serapio “strong” to justify denial of bail in a capital offense?
  • Writ of Habeas Corpus
    • Is habeas corpus a proper remedy for the delay or denial of bail hearings?
    • Was Serapio deprived of due process by the Sandiganbayan’s actions?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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