Enrile vs.

Sandiganbayan
GR No. 213847 Ⅰ 2015

FACTS:
Juan Ponce Enrile and several others was charged with plunder with the Sandiganbayan. On the
same day that the warrant for his arrest was issued, Enrile voluntarily surrendered and was later on
confined at the Philippine National Police General Hospital (PNPGH). Thereafter, Enrile filed his
Motion for Detention at the PNPGH, and his Motion to Fix Bail, claiming with the Sandiganbayan that
he should be allowed to post bail because: (a) the Prosecution had not yet established that the
evidence of his guilt was strong; (b) although he was charged with plunder, the penalty as to him
would only be reclusion temporal, not reclusion perpetua; and (c) he was not a flight risk, and his age
and physical condition must further be seriously considered. The Sandiganbyan denied the motion.

ISSUE:
Whether the Sandiganbayan gravely abused its discretion in denying Enrile’s motion.

RULING:
Yes. It is worthy to note that bail is not granted to prevent the accused from committing additional
crimes. The purpose of bail is to guarantee the appearance of the accused at the trial, or whenever so
required by the trial court. The amount of bail should be high enough to assure the presence of the
accused when so required, but it should be no higher than is reasonably calculated to fulfill this
purpose. Thus, bail acts as a reconciling mechanism to accommodate both the accused’s interest in
his provisional liberty before or during the trial, and the society’s interest in assuring the accused’s
presence at trial.

In our view, his social and political standing and his having immediately surrendered to the authorities
upon his being charged in court indicate that the risk of his flight or escape from this jurisdiction is
highly unlikely. His personal disposition from the onset of his indictment for plunder, formal or
otherwise, has demonstrated his utter respect for the legal processes of this country. We also do not
ignore that at an earlier time many years ago when he had been charged with rebellion with murder
and multiple frustrated murder, he already evinced a similar personal disposition of respect for the
legal processes and was granted bail during the pendency of his trial because he was not seen as a
flight risk. With his solid reputation in both his public and his private lives, his long years of public
service, and history’s judgment of him being at stake, he should be granted bail. The currently fragile
state of Enrile’s health presents another compelling justification for his admission to bail, but which the
Sandiganbayan did not recognize. Accordingly, we conclude that the Sandiganbayan arbitrarily
ignored the objective of bail to ensure the appearance of the accused during the trial; and
unwarrantedly disregarded the clear showing of the fragile health and advanced age of Enrile. As
such, the Sandiganbayan gravely abused its discretion in denying Enrile’s Motion To Fix Bail. Grave
abuse of discretion, as the ground for the issuance of the writ of certiorari, connotes whimsical and
capricious exercise of judgment as is equivalent to excess, or lack of jurisdiction.