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CRIM LAW 2 - Napoles vs. Sandiganbayan
CRIM LAW 2 - Napoles vs. Sandiganbayan
Facts:
In 2013, the Office of the Ombudsman received: (1) a Complaint from its Field
Investigation Office; and (2) 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. After the Ombudsman Special
Panel of Investigators established probable cause, complaints were brought before the
Sandiganbayan.
Napoles filed a Petition for Bail claiming that the prosecution's evidence was
inadequate to establish her guilt beyond a reasonable doubt. Hearings on bail were held
by the Sandiganbayan. Napoles did not submit any witnesses or any evidence, although
the prosecution called numerous witnesses. Following that, the Sandiganbayan rejected
Napoles' motion for reconsideration as well as her bail petition. Hence, this petition for
certiorari under Rule 65 alleging grave abuse of discretion on the part of the
Sandiganbayan.
Issue:
Whether the Sandiganbayan erred in denying the Petition for Bail.
Ruling:
No. The Court ruled that Sandiganbayan did not err in denying the petition for
bail. 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.
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.