Case Summary (G.R. No. 218232)
Application to Cambe and Napoles
• The Sandiganbayan summarized nine prosecution witnesses and voluminous documentary evidence, including:
– Whistleblowers’ detailed testimonies of money deliveries to Cambe (₱103 million proven to have passed through him)
– AMLC findings on NGO accounts under Napoles’s control
– COA report on ghost projects and fake suppliers
• Defense challenged signature authenticity and hearsay, but the court found no reason to discredit the witnesses or expert testimony, and properly weighed the totality of evidence.
• Supreme Court en banc held no grave abuse of discretion: the Sandiganbayan reasonably found “strong evidence” of conspiracy to commit plunder and properly denied bail to Cambe and Napoles.
Withdrawal of Revilla’s Bail Petition
• Revilla withdrew his certiorari petition on bail (G.R. No. 218232), reserving the right to pursue remedies at trial. The Court deemed the withdrawal as rendering moot any ruling on his bail petition.
Transfer of Detention Facilities
• RA 6975 authorizes the PNP to detain arrestees in PNP Custodial Centers; Rules of Court require delivery to “nearest police station or jail,” but do not limit detention to BJMP-run jails.
• Sandiganbayan found no cogent reason to move Revilla and Cambe to BJMP facilities or that they enjoyed “special treatment” at Camp Crame.
• Supreme Court found no abuse of discretion: Section 24 of RA 6975 and PNP Operational Manual sanction PNP custodial detention; BJMP-only argument unconvincing.
Writ of Preliminary Attachment
• Under Rules 57 & 127, attachment may issue ex parte when a public officer accused of embezzlement or fraudulent conversion conceals or may dispose of assets, and a prima facie case exists. The filing of a plunder Information carries with it a civil action for recovery.
• Office of the Ombudsman alleged Revilla closed accounts on news of PDAF scandal; AMLC report confirmed fund terminations; prosecutors fil
Case Syllabus (G.R. No. 218232)
Background and Consolidation
- Five separate certiorari petitions before the Supreme Court En Banc were docketed and later consolidated:
• G.R. No. 218232 (Revilla) – challenges denial of bail in SB-14-CRM-0240
• G.R. No. 218235 (Cambe) – challenges denial of bail in the same plunder case
• G.R. No. 218266 (Napoles) – challenges denial of bail in the same plunder case
• G.R. No. 218903 (People of the Philippines) – challenges denial of motion to transfer detainees Revilla and Cambe
• G.R. No. 219162 (Revilla) – challenges grant of writ of preliminary attachment against his assets - On 4 August 2015 the Court En Banc ordered consolidation of all five petitions for joint resolution.
Facts of the Case
- On 5 June 2014, the Office of the Ombudsman filed an Information in the Sandiganbayan alleging that Senators’ PDAF (Priority Development Assistance Fund) allocations from 2006 to 2010 were diverted through bogus NGOs controlled by Janet Lim Napoles.
- Petitioners Revilla (Senator), Cambe (his chief of staff), and Napoles were charged with Plunder under Section 2 of Republic Act No. 7080, as amended, for conspiring to amass at least PHP 224,512,500 in kickbacks.
- Conspiracy scheme described in the Amended Information:
• Projects endorsed by Revilla and Cambe to government agencies were implemented by Napoles’s ghost NGOs.
• NGOs received SARO-funded checks; proceeds were misappropriated and shared among Napoles (32–40%), Revilla (50% of project cost), and Cambe (5%). - Upon issuance of arrest warrants, Revilla and Cambe voluntarily surrendered and elected detention at the PNP Custodial Center. Napoles likewise surrendered.
- All three filed separate motions for bail and underwent summary bail hearings in which the prosecution presented nine witnesses (COA, DBM officials, whistleblowers, NBI and AMLC officers) and voluminous documentary evidence.
Issues Presented
- G.R. No. 218232 (Revilla): Whether the Sandiganbayan gravely abused its discretion in denying bail despite alleged insufficient evidence of guilt.
- G.R. No. 218235 (Cambe):
• Whether the lower court applied the correct quantum of proof (“strong evidence” vs. “proof evident”) in denying bail.
• Whether reliance on “totality of evidence” was erroneous.
• Whether the denial