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Title
Republic of the Philippines vs. Sandiganbayan

Case Ponente Decision Date


G.R. No. 232724-27 LEONEN, J Feb 15, 2021

The Supreme Court ruled in favor of the Sandiganbayan,


a!rming its denial of the Anti-Money Laundering Council's
motion to quash a subpoena for bank records in a criminal case
involving former First Gentleman Jose Miguel T. Arroyo's alleged
involvement in the anomalous purchase of two secondhand
helicopters by the Philippine National Police.

Case Digest (G.R. No. 232724-27)

Facts:

The case of Republic v. Sandiganbayan involves the criminal case


against former First Gentleman Jose Miguel T. Arroyo for his alleged
involvement in the anomalous purchase of two secondhand
helicopters by the Philippine National Police. The Anti-Money
Laundering Council (AMLC) was requested to disclose bank records
related to the case. However, the AMLC refused to disclose the bank
records, citing con"dentiality provisions under the Anti-Money
Laundering Act. The Sandiganbayan, the court handling the case,
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denied the AMLC's motion to quash the subpoena for the bank
records. The court ruled that the importance of the documents
outweighed the AMLC's misgivings on disclosure.

Issue:

The main issue in this case is whether the AMLC is required to


disclose the bank records requested by the court, despite the
con"dentiality provisions under the Anti-Money Laundering Act.

Ruling:

The court a!rmed the Sandiganbayan's denial of the AMLC's motion


to quash the subpoena for the bank records.

Ratio:

The court held that the AMLC is not covered by the con"dentiality
provisions under the Anti-Money Laundering Act. The AMLC is
tasked with investigating and prosecuting money laundering
o#enses, and therefore, it is not prohibited by law from disclosing
the bank records. The court also noted that the owner of the bank
account, Lionair, had waived its rights to con"dentiality and granted
permission for the disclosure of the records. This further supports
the court's decision to allow the disclosure of the bank records.
Additionally, the court found that the subpoena provided a
reasonable description of the documents sought, addressing the
AMLC's argument that the description was insu!cient. Overall, the
court considered the importance of the documents in the criminal
case against Jose Miguel T. Arroyo and concluded that the AMLC's
concerns about con"dentiality were outweighed by the need for
disclosure in the interest of justice.
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