GR 213455; (August, 2015) (Digest)
G.R. No. 213455, August 11, 2015
Juan Ponce Enrile, Petitioner, vs. People of the Philippines, Hon. Amparo M. Cabotaje-Tang, Hon. Samuel R. Martires, and Hon. Alex L. Quiroz of the Third Division of the Sandiganbayan, Respondents.
FACTS
On June 5, 2014, an Information for plunder was filed against petitioner Juan Ponce Enrile and others before the Sandiganbayan, alleging that from 2004 to 2010, they conspired to amass at least Php172,834,500.00 in ill-gotten wealth through kickbacks from Janet Lim Napoles in connection with Enrile’s Priority Development Assistance Fund (PDAF). Enrile filed motions, including a motion to dismiss and an ad cautelam motion for bail, which the Sandiganbayan denied on July 3, 2014, issuing warrants of arrest. On July 10, 2014, Enrile filed a Motion for Bill of Particulars. During the hearing on July 11, 2014, the Sandiganbayan orally denied this motion, stating the desired details were evidentiary and substantial reiterations of arguments already raised. After an oral motion for reconsideration was also denied, Enrile was arraigned and a “not guilty” plea was entered on his behalf. Enrile then filed a petition for certiorari, arguing the Sandiganbayan committed grave abuse of discretion in denying his Motion for Bill of Particulars, violating his constitutional right to be informed of the nature and cause of the accusation.
ISSUE
Whether the Sandiganbayan acted with grave abuse of discretion amounting to lack or excess of jurisdiction in denying petitioner’s Motion for Bill of Particulars.
RULING
The Supreme Court DENIED the petition. The Court held that the Sandiganbayan did not commit grave abuse of discretion. The Information sufficiently alleged the elements of the crime of plunder. It stated the ultimate facts: the period (2004-2010), the amount amassed (Php172,834,500.00), the overt acts (receiving kickbacks from Napoles in consideration of endorsing her NGOs for PDAF-funded projects, which were ghost or fictitious), and the conspiracy among the accused. The details sought by Enrile in his Motion for Bill of Particulars—such as the specific amounts received on each occasion, dates, places, persons who delivered and received the money, and descriptions of each project—were evidentiary matters not required to be stated in the Information. The purpose of a bill of particulars is to clarify ambiguous allegations, not to supply evidentiary details. The allegations in the Information were clear enough to enable Enrile to prepare his defense and to bar a subsequent prosecution for the same offense. Therefore, the Sandiganbayan’s denial of the motion was a proper exercise of its discretion.