AN ACCUSSED IN ANY CASE MAY BE GRANTED BAIL IF THERE EXIST/S SPECIAL,

HUMANITARIAN AND COMPELLING CIRCUMSNTACE/S, PROVIDED THAT HE WILL NOT

BE A FLIGHT RISK OR A DANGER TO THE COMMUNITY

Juan Ponce Enrile v Sandiganbayan

G.R. No. 213847, August 18, 2015
Bersamin, J:

For alleged involvement in the misuse of the Priority Development Assistance Fund (PDAF),
Senator Enrile was charged with plunder by the Office of the Ombudsman before the
Sandiganbayan. On the day the Sandiganbayan released its Warrant of Arrest, Enrile also
voluntarily surrendered in Camp Crame, Quezon City, and was later confined at the PNP General
Hospital due to his medical condition.

Enrile filed a Motion for Detention at PNP General Hospital and a Motion to Fix Bail arguing that
1) the Prosecution has not yet established that that the evidence of his guilt was strong, 2) that
because of his old age and the fact that he voluntarily surrendered, his eventual penalty if found
guilty is only reclusion temporal instead of reclusion perpetua, and 3) that his medical conditions
as well as the fact that he was not a flight risk are special circumstances that warranted his
provisional release. The Sandiganbayan denied his motion on the ground that no determination
of the strength of the evidence of the Prosecution has been made yet because no bail hearing
has been scheduled, and that mitigating circumstances are not considered in determining whether
an offense is bailable.

Enrile filed a petition for certiorari, raising the same grounds he raised before the Sandiganbayan
to justify his release.

Issue:

Is there sufficient justification to grant him bail?

Held:

Yes. In any case, there is the presence of a special, humanitarian and compelling circumstance
i.e. his bad medical condition. The main purpose of bail is to ensure that the accused appears
before trial whenever so required by the court. Medical doctors from the Philippine General
Hospital, as well as those from the PNP General Hospital, concur that the detainment of Enrile
will be detrimental to his health and dangerous to his life. Denying him bail would be
counterintuitive to its main purpose of ensuring his presence during trial.

The Philippines is mindful of its responsibility to the Universal Declaration of Human Rights and
should authorize the grant of bail to those charged in criminal proceedings as well as extradites
upon a clear showing that 1) the detainee is not a flight risk or a danger to the community, and 2)
there is a special, humanitarian and compelling circumstance. Because of Enriles solid reputation
in both his public and private lives, his long years of public service, it is less likely that he will flee
and therefore must be granted bail.