GR 213847 So; (August, 2015) (Digest)
G.R. No. 213847, August 18, 2015
Juan Ponce Enrile, Petitioner, vs. Sandiganbayan (Third Division), and People of the Philippines, Respondents.
FACTS
On June 5, 2014, Senator Juan Ponce Enrile was charged with plunder, punishable by reclusion perpetua to death under Republic Act No. 7080. On June 10, 2014, he filed an Omnibus Motion before the Sandiganbayan praying to be allowed to post bail if probable cause was found. The Sandiganbayan denied this motion as premature on July 3, 2014, and issued a warrant for his arrest. On July 7, 2014, Enrile filed a Motion to Fix Bail, arguing that his age (over 70) and voluntary surrender were mitigating circumstances that would lower the imposable penalty to reclusion temporal, making bail a matter of right, and that his age and physical condition indicated he was not a flight risk. The Sandiganbayan denied this motion on July 14, 2014, 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. Enrile’s motion for reconsideration was denied on August 8, 2014, prompting the filing of the Petition for Certiorari.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion in denying petitioner’s Motion to Fix Bail.
RULING
In his dissenting opinion, Justice Leonen held that the Sandiganbayan did not commit grave abuse of discretion. The denial of the Motion to Fix Bail was proper as bail is not a matter of right for the crime of plunder where the imposable penalty is reclusion perpetua. The Sandiganbayan correctly followed procedural rules, which require a bail application and a determination that the evidence of guilt is not strong before bail can be fixed. The dissent further argued that the petitioner did not raise his medical condition as a ground for bail before the Sandiganbayan or in his petition; thus, the majority’s grant of bail on humanitarian grounds was a special accommodation without legal basis in the Constitution, statutes, or Rules of Court. Granting bail on such unraised grounds sets an unpredictable precedent, undermines the rule of law, and places undue pressure on lower courts to decide similar motions without clear legal guidance.