Napoles v.

Sandiganbayan
G.R. No. 224162 (November 7, 2017)

Topic: Rule 114: Bail

Issue: Whether or not the Sandiganbayan gravely abused its discretion amounting to lack or excess of
jurisdiction in denying Napoles’ application for bail

Held: No

Ratio: As a rule, bail may be granted as a matter of right prior to conviction.

Except (1) when it involves a capital offense and the evidence of guilt is strong; or (2) when the accused is
a flight risk. In such cases, the grant of bail is a matter of discretion.

How should a trial court exercise such discretion? The following are the duties of the trial court in
applications for bail: (1) notify the prosecutor of the hearing of the application or require him to submit his
recommendation, whether the application for bail is a matter of right or discretion; (2) where bail is a
matter of discretion, conduct a hearing on the application regardless of whether or not the prosecution
refuses to present evidence, to enable the court to exercise its sound discretion; (3) decide whether the
evidence of guilt is strong; (4) if so, discharge the accused upon the approval of the bailbond; otherwise,
petition should be denied.

In this case, Napoles was charged with Plunder which is punishable by reclusion perpetua. She cannot,
thus, be admitted to bail when the evidence of her guilt is strong. The burden of proof to show such is on
the prosecution.

The prosecution can discharge its burden by proving that the evidence shows evident proof of guilt or a
great presumption of guilt, which the Court defined in People v. Cabral as follows:

“Proof evident” or “Evident proof’ in this connection has been held to mean clear, strong evidence which
leads a well-guarded dispassionate judgment to the conclusion that the offense has been committed as
charged, that accused is the guilty agent, and that he will probably be punished capitally if the law is
administered. “Presumption great” exists when the circumstances testified to are such that the inference of
guilt naturally to be drawn therefrom is strong, clear, and convincing to an unbiased judgment and
excludes all reasonable probability of any other conclusion. Even though there is a reasonable doubt as to
the guilt of accused, if on an examination of the entire record the presumption is great that accused is
guilty of a capital offense, bail should be refused.

No grave abuse of discretion on the part of the Sandiganbayan. The Sandiganbayan scheduled hearings
to allow the parties to submit their respective pieces of evidence. The prosecution submitted numerous
testimonial and documentary evidence. Napoles, on the other hand, opted not to submit any evidence on
her behalf and relied instead on the supposed weakness of the prosecution’s evidence. The evidence of
the prosecution was summarized accordingly, effectively complying with the due process requirements. It
even extensively discussed the available evidence in relation to the elements of Plunder, which the
prosecution intended to prove point by point for purposes of demonstrating Napoles’ great presumption of
guilt.