Case Brief: Enrile v Sandiganbayan and People

G.R. No. 213847,     Aug. 18, 2015

Juan Ponce Enrile


Sandiganbayan ( 3rd division ) and People of the Philippines



Year 2014, Sen. Enrile was charged with plunder before the Sandiganbayan for their alleged involvement in the diversion and misuse of appropriation under the PDAF. When his warrant was issued, Sen. Enrile voluntarily surrendered to the CIDG and was later confined and detained at the PNP General Hospital, he then filed a motion to fix bail where he argued that:

  1. He should be allowed to post bail as a matter of right;
  2. Although charged with plunder his penalty would only be reclusion temporal considering that there are two mitigating circumstances, his voluntary surrender and that he is already at the age of 90;
  3. That he is not a flight risk and his medical condition must be seriously considered.

The Sandiganbayan however, denied his motion on the grounds that:

  1. He is charged with a capital offense;
  2. That it is premature for the Court to fix the amount of his bail because the prosecution have not yet presented its evidences.

Sen. Enrile then filed a certiorari before the Supreme Court.


Whether or not the Sandiganbayan acted with grave abuse of discretion amounting to lack or excess of jurisdiction for denying his motion to fix bail?


Yes, the Supreme Court held that the Sandiganbayan arbitrarily ignored the objective of bail and unwarrantedly disregarded Sen. Enrile’s fragile health and advanced age. Bail is a matter right and is safeguarded by the constitution, its purpose is to ensure the personal appearance of the accused during trial or whenever the court requires and at the same time recognizing the guarantee of due process which is the presumption of his innocence until proven guilty. The Supreme Court further explained that Bail for the provisional liberty of the accused, regardless of the crime charged should be allowed independently of the merits charged, provided his continued incarceration is injurious to his health and endanger his life. Hence, the Sandiganbayan failed to observe that if Sen. Enrile be granted the right to bail it will enable him to have his medical condition be properly addressed and attended, which will then enable him to attend trial therefore achieving the true purpose of bail.


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