Case Summary (A.M. No. MTJ-11-1786)
Procedural History
- Enrile was indicted for plunder (penalty: reclusion perpetua to death) and arrested.
- He filed a Motion to Fix Bail (July 7, 2014), invoking age and health as mitigating circumstances and asserting low flight risk.
- Sandiganbayan denied fixation as premature (July 14, 2014), holding that bail as of right arises only after a finding that evidence of guilt is not strong.
- Enrile sought reconsideration of that denial; Sandiganbayan maintained its view (August 8, 2014).
- En Banc granted Enrile’s certiorari petition (August 18, 2015), annulling Sandiganbayan resolutions and ordering bail (P1,000,000).
- The People moved for reconsideration before the Supreme Court, challenging legal and procedural bases for bail.
Motion for Reconsideration: Grounds
• Alleged factual misplacement: bail hinged on non-flight risk, fragile health, and personal circumstances unique to Enrile.
• Claimed radical alteration of constitutional and procedural bail principles for crimes punishable by reclusion perpetua.
• Accused deviation from mandated procedure requiring determination of evidentiary strength before bail.
• Argument that health and age are relevant only to bail amount, not entitlement.
• Assertion of due process violation: decision rested on grounds not raised or contested in petition.
• Equal protection concern: preferential treatment accorded to Enrile.
Opportunity to Contest Health Findings
The Court found that:
• Enrile disclosed his frail condition via Omnibus Motion (June 10, 2014), Motion to Fix Bail, and supplemental pleadings; medical certificates and PGH solicitations were part of the record.
• Prosecution filed Consolidated Opposition to all health-related pleadings and had reasonable chance to refute medical opinions.
• Sandiganbayan solicited PGH doctors’ input on Enrile’s state, which formed part of the certiorari record.
Thus, the People were not deprived of a fair opportunity to contest health evidence.
Inquiry into Flight Risk and Personal Circumstances
• Primary purpose of bail under Rule 114, Sec. 2 is to secure appearance; flight risk is the principal consideration.
• Court weighed Enrile’s advanced age (92), unstable health, long public service, and reputation as indicators of negligible flight risk.
• Precedents (Villaseñor v. Abaño, Stack v. Boyle) confirm that personal circumstances influencing flight probability are proper bail factors.
Nature and Purpose of Bail under the 1987 Constitution
• Art. III, Sec. 13 guarantees bail as of right except for offenses carrying reclusion perpetua when evidence is strong.
• Bail reconciles the accused’s presumption of innocence and society’s interest in trial appearance without undue pretrial detention.
• Bail is not punitive, nor a preventive-detention tool; it secures court jurisdiction and protects individual liberty pending final adjudication.
Regulatory Framework for Bail and Judicial Discretion
• Rule 114 governs bail procedure, distinguishing between bailable offenses (matter of right) and those punishable by reclusion perpetua (matter of discretion).
• Section 7 (Rule 114) bars bail when evidence is strong; otherwise bail remains constitutional right.
• Section 9 lists factors for fixing amount: health, character, flight risk, weight of evidence, financial ability, etc.
Application of Legal Principles to Enrile’s Case
• No binding prohibition in Constitution or Rules against discretionary bail to reclusion-perpetua-charged accused absent strong evidence.
• Court, as rule-making authority, may employ equity in penumbral areas not expressly forbidden by Constitution when huma
Case Syllabus (A.M. No. MTJ-11-1786)
Facts of the Case
- Senator Juan Ponce Enrile was charged on June 5, 2014 with plunder under R.A. No. 7080, an offense punishable by reclusion perpetua to death.
- Enrile was arrested on July 3, 2014 and detained at the PNP General Hospital due to advanced age and frail health.
- He filed:
• An Omnibus Motion (June 10, 2014) seeking bail if probable cause was found.
• A separate Motion to Fix Bail (July 7, 2014), citing mitigating circumstances of advanced age (91) and voluntary surrender, and claiming he was not a flight risk.
• A Motion for Detention at the PNP General Hospital (July 4, 2014) for medical reasons. - The Sandiganbayan heard the hospital-detention motion on July 9, 2014 and allowed Enrile to remain admitted; it later denied the Motion to Fix Bail as premature (July 14, 2014).
- Enrile’s petition for certiorari to annul those resolutions was granted by this Court on August 18, 2015, ordering his provisional release on P1,000,000 cash bail.
Procedural History
- Sandiganbayan (Third Division)
• July 9, 2014 – Ordered Enrile’s continued hospital detention.
• July 14, 2014 – Denied Motion to Fix Bail as premature.
• August 8, 2014 – Denied Motion for Reconsideration of the denial to fix bail. - Supreme Court
• August 18, 2015 – Granted certiorari, annulled Sandiganbayan resolutions, ordered provisional release on P1,000,000 bail.
• People moved for reconsideration, arguing multiple legal infirmities. - Supreme Court En Banc
• July 12, 2016 – Denied the People’s Motion for Reconsideration for lack of merit.
Issues
- Whether the August 18, 2015 decision granting provisional bail to Enrile:
• Contravened constitutional and procedural principles governing bail for offenses punishable by reclusion perpetua.
• Ignored the mandatory procedure requiring a determination that evidence of guilt was not strong.
• Disregarded the need to consider strength of evidence against the accused.
• Violated due process by relying on grounds not raised in the petition.
• Breached equal protection by allegedly granting preferential treatment to Enrile.
Grounds Raised by the People for Reconsideration
- The decision was based on factual findings (no flight risk; fragile health; unique personal grounds) absent sufficient constitutional or