G.R. No. 213847, August 18, 2015
Juan Ponce Enrile, Petitioner, vs. Sandiganbayan (Third Division), and People of the Philippines, Respondents.

FACTS

Petitioner Juan Ponce Enrile was charged with plunder before the Sandiganbayan in relation to the alleged misuse of PDAF funds. After the Sandiganbayan issued a warrant for his arrest, Enrile voluntarily surrendered and was confined at the PNP General Hospital. He filed a Motion to Fix Bail, arguing he was entitled to bail because: (a) the prosecution had not established that the evidence of his guilt was strong; (b) the maximum penalty imposable on him, considering his age (over 70) and voluntary surrender as mitigating circumstances, would only be reclusion temporal, not reclusion perpetua; and (c) he was not a flight risk given his age, physical condition, and social standing. The Sandiganbayan denied his motion, ruling it was premature as no bail application had been filed and no determination had been made on whether the evidence of guilt was strong. It also held that mitigating circumstances are not considered for purposes of bail but only during penalty imposition after trial. Enrile’s motion for reconsideration was likewise denied. He then filed a petition for certiorari before the Supreme Court, assailing the Sandiganbayan’s resolutions for grave abuse of discretion.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion in denying Enrile’s Motion to Fix Bail.

RULING

Yes. The Supreme Court granted the petition. The Court held that the right to bail is a constitutional right, available to all persons except those charged with offenses punishable by reclusion perpetua, life imprisonment, or death when evidence of guilt is strong. For the exception to apply, two conditions must concur: (1) the offense is punishable by reclusion perpetua, life imprisonment, or death; and (2) evidence of guilt is strong. The prosecution bears the burden of proving clearly and conclusively that these conditions are present. In this case, the prosecution failed to meet this burden. The Court emphasized that bail is intended to ensure the accused’s appearance at trial and is not a preventive detention measure. Considering Enrile’s age, frail health, and his voluntary surrender, he is not a flight risk. The Court also noted that while the determination of whether evidence of guilt is strong is a matter of judicial discretion, such discretion must be exercised without grave abuse. The Sandiganbayan’s denial of bail without conducting a hearing to determine the strength of the evidence, and its rigid stance on the non-consideration of mitigating circumstances for bail purposes, constituted a refusal to exercise proper discretion. Consequently, the Court ordered the Sandiganbayan to determine, with dispatch, whether Enrile may be granted bail based on the standards set forth in the decision.