G.R. No.

224162
JANET LIM NAPOLES, Petitioner
vs.
SANDIGANBAYAN (THIRD DIVISION), Respondent
REYES, JR., J.:

FACTS:
In 2013, the Office of the Ombudsman received a Complaint from its Field Investigation Office;
and a recommendation from the NBI; charging Janet Lim Napoles, former Sen. Juan Ponce Enrile, his
Chief of Staff, Atty. Jessica Lucila Reyes and several other individuals with the crime of Plunder under RA
7080 and violations of the Anti-Graft and Corrupt Practices Act (RA 3019) for allegedly misappropriating
former Sen. Enrile’s PDAF through fictitious NGO’s. The Ombudsman Special Panel of Investigators found
probable cause and thereafter Information’s against them were filed before the Sandiganbayan. In 2014,
Napoles filed a Petition for Bail arguing that the evidence of the prosecution is insufficient to prove her
guilt beyond reasonable doubt. The Sandiganbayan conducted bail hearings. The prosecution presented
several witnesses but Napoles did not present any nor any other evidence. The Sandiganbayan
thereafter denied the Petition for Bail of Napoles as well as her Motion for Reconsideration. Hence, this
petition for certiorari under Rule 65 alleging grave abuse of discretion on the part of the Sandiganbayan.

ISSUE:
WON the Sandiganbayan gravely abused its discretion amounting to lack or excess of jurisdiction
in denying Napoles' application for bail.

RULING: NO
RATIO DECIDENDI:
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.

Right to Bail
As a rule, bail may be granted as a matter of right prior to conviction.
Exception:
1. when it involves a capital offense and the evidence of guilt is strong;
2. when the accused is a flight risk. In such cases, the grant of bail is a matter of discretion.

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.