Title
Enrile vs. Sandiganbayan, 3rd Division
Case
G.R. No. 213847
Decision Date
Jul 12, 2016
A 91-year-old former senator sought bail due to advanced age and frail health; the Supreme Court granted release, citing humanitarian grounds and low flight risk, despite charges of plunder punishable by life imprisonment.

Case Summary (G.R. No. 213847)

Procedural Posture

The Supreme Court, sitting en banc, previously granted the petition for certiorari, annulled and set aside the Sandiganbayan resolutions dated July 14, 2014 and August 8, 2014, ordered Enrile’s provisional release upon posting of a P1,000,000 cash bond, and directed his immediate release unless detained for some other lawful cause. The People moved for reconsideration, urging reversal on constitutional, procedural, and evidentiary grounds; the Court denied the Motion for Reconsideration for lack of merit.

Applicable Law and Constitutional Basis

The Court applied the 1987 Constitution (Article III, Section 13) as governing law: “All persons, except those charged with offenses punishable by reclusion perpetua when evidence of guilt is strong, shall, before conviction, be bailable….” The Court also relied on Rule 114 of the Rules of Court (including provisions addressing bail as a right, the exception for capital offenses or those punishable by reclusion perpetua when evidence is strong, and guidelines for fixing the amount of bail), and on relevant jurisprudence cited in the opinion.

Central Legal Questions

The principal legal questions were: (1) whether the Supreme Court’s grant of provisional release improperly altered constitutional and procedural principles on bail; (2) whether the grant was legally justified given Enrile’s charge of plunder (an offense punishable by reclusion perpetua) and the constitutional exception; (3) whether humanitarian factors (advanced age and frail health) and low flight risk could justify bail without a Sandiganbayan bail hearing determining that evidence of guilt was not strong; and (4) whether the People were denied due process or equal protection by the Court’s decision.

Majority Rationale — Notice, Record, and Opportunity to Contest

The Court held that the prosecution was not deprived of reasonable opportunity to contest Enrile’s health and other factual assertions. Enrile had put his health before the Sandiganbayan through an Omnibus Motion (June 10, 2014), a Motion to Fix Bail (July 7, 2014), supplemental pleadings, and medical certificates; the Sandiganbayan itself solicited medical opinions from the Philippine General Hospital (PGH). These medical findings were part of the record before the Supreme Court. Because the prosecution had these materials in the record and had earlier filed oppositions, the Court concluded the People were not kept in the dark and had opportunities to rebut the medical and factual claims.

Majority Rationale — Purpose of Bail and Flight Risk Emphasis

The Court reiterated the constitutional and jurisprudential understanding that the principal purpose of bail is to secure the accused’s appearance at trial and preserve the presumption of innocence by avoiding pretrial incarceration except where the Constitution and rules permit otherwise. Citing authorities (including Stack v. Boyle and local precedents), the Court emphasized that the exception to bail for those charged with offenses punishable by reclusion perpetua is calibrated to the probability of flight: the greater the flight risk, the stronger the justification for denying bail. The Court found the records supported a determination that Enrile’s risk of flight was low to nil.

Majority Rationale — Humanitarian Considerations and Medical Evidence

The Court accepted the uncontested medical evidence from PGH, especially the testimony and certifications of Dr. Jose C. Gonzales, describing multiple serious geriatric and cardiovascular conditions, respiratory disease, ophthalmologic conditions requiring ongoing treatment, and other comorbidities. The majority treated these conditions and Enrile’s advanced age as material facts reducing the likelihood of flight and as humanitarian grounds supporting provisional release. The medical findings were not contested by the prosecution in the Motion for Reconsideration and therefore carried weight in the Court’s evaluation.

Majority Rationale — Equity, Historical Precedent, and Practical Concerns

The Court noted precedent allowing humanitarian considerations in bail determinations (for example, Dela Rama) and analogous foreign authorities. It invoked the Court’s equitable jurisdiction to supplement legal remedies where necessary to effectuate constitutional protections of liberty, so long as equity does not contravene positive law. The majority also observed practical medical concerns (including limitations of PNP hospital facilities for emergencies) and the documented risks of prolonged hospital confinement to elderly patients. On this composite of legal, medical, and practical considerations, the Court concluded there were proper legal and factual bases to admit Enrile to provisional liberty on bail.

Rejection of Prosecutor’s Due Process and Equal Protection Arguments

The Court rejected the People’s argument that the grant of provisional release denied the prosecution due process because the decision relied on grounds not raised in the petition. The Court found the health evidence and related assertions were before the Sandiganbayan and in the record, and thus the People had a reasonable opportunity to contest them. The Court also rejected the charge of preferential treatment and equal protection violation, holding that Enrile’s circumstances (advanced age, frail health, public service record, reputation) legitimately distinguished his case and that the People did not demonstrate a class of similarly situated nonagenarians in custody who were denied bail such that an equal protection violation would be established.

Separate Concurring Opinion (Justice Brion) — Emphasis on Equity and Judicial Power

Justice Brion wrote a separate concurring opinion explaining his support for the denial of reconsideration. He emphasized the constitutional protection of life and liberty, the presumption of innocence, and the role of bail in implementing those guarantees. He advanced a view that the Supreme Court may, within its judicial power and when compelled by the higher interest of justice, exercise equitable considerations to supplement procedural rules—particularly where the Constitution does not absolutely prohibit discretionary grant of bail for serious offenses. He highlighted the uncontested medical findings, the inadequacy of detention-hospital facilities to meet emergency needs, and the absence of direct evidence that Enrile personally received kickbacks in the underlying adminis

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