Enrile Case.docx

Facts of the Case: This case involved a petition for certiorari as filed by Senator Juan Ponce Enrile, assailing the resolutions of the Sandiganbayan where he had been charged with plunder. Enrile contends that the resolutions were issued with grave abuse of discretion, amounting to lack or excess of jurisdiction. On June 5, 2014, the Ombudsman charged Enrile with plunder on the basis of their involvement in the misuse of appropriations under the Priority Development Assistance Fund (PDAF). Enrile, in response, filed an Omnibus motion and supplemental opposition - claiming that he should be allowed to post bail should probable cause be found against him. These motions were heard by the Sandiganbayan, but were denied on the ground of its prematurity. The Sandiganbayan then ordered the arrest of Enrile, who voluntarily surrendered to Dir. Benjamin Magalong of the Criminal Investigation and Detection Group in Camp Crame, Quezon City. Later on, he was confined in the PNP General Hospital. Enrile argued that he should be allowed to post bail for the following reasons: (a) The prosecution had yet to establish that the evidence of his guilt was strong, (b) Although he was charged with plunder, the penalty imposable on him is reclusion temporal, and (c) he is not a flight risk. On July 14, the Sandiganbayan in its first resolution denied Enrile’s motion to Fix bail on the ground of prematurity. It later on issued a second resolution denying Enrile’s reconsideration. Enrile thus raises the following grounds in support of his petition for certiorari: (a) Before judgment of the Sandiganbayan, and before it is proven that he is punishable by reclusion perpetua wherein evidence of guilt is strong, he is bailable as a matter of right; (b) The prosecution failed to show that Enrile, if ever found guilty, would be punishable by reclusion perpetua, thus he is bailable as a matter of right; (c) The prosecution failed to show clearly and conclusively that evidence of Enrile’s guilt is strong, he is bailable as a matter of right; (d) Anyway, Enrile is not a flight risk.

Issue: W/N Enrile should be granted bail considering the factual circumstances of the case? Ruling: The Supreme court ruled that the Sandiganbayan arbitrarily ignored the objective of bail, which is to ensure the appearance of the accused during trial; unwarrantedly disregarding the clear showing of fragile health and advanced age of Enrile. It offered the following justifications for its ruling

First, the court said that the right to bail protects the right of the accused to due process, and to be presumed innocent. More importantly, it is to ensure that the accused appeared during trail. Secondly, the court stated the doctrine that Bail may be granted as a matter of right, or matter of discretion. As provided for in Section 7 of Rule 114 of the Rules of Court, no person charged with a capital offense when evidence of guilt is strong shall be admitted to bail, regardless of the stage of the criminal prosecution. Third, admission to bail in offenses punished by death, life imprisonment, or reclusion perpetua is subject to JUDICIAL DISCRETION. In cases where bail is a matter of discretion, conduct of a hearing for bail, which may be summary or otherwise, wherein it will be determined whether or not evidence of guilt against accused is strong, Lastly, the court stated that Enrile’s poor health justifies his admission to bail. It said that the Philippines has the responsibility of protecting the right of every person to liberty and due process. Philippine authorities are under the obligation to make available to every person under detention such remedies, which safeguard their fundamental right to liberty. The court considered the social and political standing of Enrile, his having surrendered voluntarily, and the low chance of him being a flight risk. His personal disposition was also looked at.