ENRILE V SANDIGANBAYAN

G.R. No. 213847. August 18, 2015

Doctrine:
The strength of the Prosecution's case, albeit a good measure of the accused's
propensity for flight or for causing harm to the public, is subsidiary to the primary objective
of bail, which is to ensure that the accused appears at trial. Right to bail is afforded in Sec.
13, Art III of the 1987 Constitution and repeted in Sec. 7, Rule 114 of the Rules of Criminal
Procedure to wit: No person charged with a capital offense, or an offense punishable by
reclusion perpetua or life imprisonment, shall be admitted to bail when evidence of guilt is
strong, regardless of the stage of the criminal prosecution.

Facts:
On June 5, 2014 Senator Juan Ponce Enrile was charged by the Office of the
Ombudsman with plunder in the Sandiganbayan on the basis of his purported involvement in
the diversion and misuse of appropriations under the Priority Development Assistance Fund
(PDAF). The case is a petition for certiorari to annul the decision of the Sandiganbayan
denying his Motion to fix bail and Motion for Reconsideration on the following grounds: (a)
The prosecution failed to show conclusively that Enrile, if ever convicted, is punishable by
reclusion perpetua; (b) The prosecution failed to show that evidence of Enriles guilt is
strong; (c) Enrile is not a flight risk.

Issue:
Whether or not Enrile can bail?

Ruling:

Yes. The purpose of the bail is to guarantee the appearance of the accused at the
trial. It is the Philippines responsibility in the international community under the Universal
Declaration of Human Rights .of protecting and promoting the right of every person to
liberty and due processunder the obligation to make available to every person under
detention such remedies which safeguard their fundamental right to liberty. These remedies
include the right to be admitted to bail.

Enrile is not a flight risk because of his social and political standing and his having
immediately surrendered to the authorities upon being charged in court. The currently
fragile state of Enriles health is a compelling justification for his admission to bail. (Chronic
hypertension, diffuse atherosclerotic cardiovascular disease, Atrial and Ventricular
Arrhythmia, etc.)
REAS v. RELACION
[A.M. No. P-05-2095 [Formerly A.M. OCA IPI No. 05-2085-P], February 09 : 2011]

Doctrine:
Every official or employee of the Judiciary is ever accountable in the performance of
official duties as well as in dealing with others.

Facts:
Reas alleged in his complaint that by prior arrangement, the Clerk of Court of the RTC
(COC) delivered to the Cebu CFI Community Cooperative (Cooperative) the salary checks of
court personnel with outstanding obligations with the Cooperative to pay for their loans; that
his salary check for the period of September 1 to 15, 2004 in the amount of P4,280.00 was
delivered by the COC to the Cooperative for that purpose; that when he asked for the receipt
corresponding to his payment, the Cooperative informed him that his salary check had been
"inadvertently surrendered" to Relacion after the latter had harassed the Cooperative "to a
point of violence" to release his (Relacion) own check for that period; that Relacion did not
return the salary check to the Cooperative despite repeated demands; that when he
confronted Relacion, the latter admitted taking his salary check; that Relacion mauled him
when he refused Relacion's offer to pay his salary check with Relacion's JDF check; and that
it was only after the Cooperative confronted Relacion that the latter paid his salary check.

Issue:
Whether or Not Relacion committed misconduct in not returning Reas check
Whether or Not a compromise agreement terminate administrative matters

Held:
(1) Yes. According to Civil Service Commission v. Ledesma, misconduct is a
transgression of some established rule of action, an unlawful behavior, or gross
negligence by a public officer. The misconduct is grave if it involves any of the
additional elements of corruption, willful intent to violate the law, or disregard of
long-standing rules, which must be established by substantial evidence.
Otherwise, the misconduct is only simple. Relacion did not maliciously or
deliberately take Reas' salary check rendered him liable only for simple
misconduct.

(2) No. Three reasons justify the continuation of the administrative matter despite the
compromise agreement or the forgiveness. One, the Court's disciplinary authority
is not dependent on or cannot be frustrated by the private arrangements entered
into by the parties. Two, public interest is at stake in the conduct and actuations
of the officials and employees of the Judiciary. Accordingly, the efforts of the Court
in improving the delivery of justice to the people should not be frustrated and put
to naught by any private arrangements between the parties. And, three, the
Court's interest in the affairs of the Judiciary is a paramount concern that bows to
no limits.
RE: EMPLOYEES INCURRING HABITUAL TARDINESS IN THE SECOND
SEMESTER OF 2009

A.M. No. 2010-11-SC March 15, 2011

Doctrine:

Employees of the Judiciary should observe punctuality in reporting to work. Tardiness,

if habitual, prejudices the efficiency of the service being rendered by the Judiciary to the
people, and cannot be tolerated.

Facts:

On July 5, 2010, the OAS directed the concerned employees to explain in writing why
no administrative disciplinary action should be taken against them for their habitual
tardiness during the covered period, which habitual tardiness was in violation of Civil Service
Commission (CSC) Memorandum Circular No. 04, Series of 1991, viz: An employee shall be
considered habitually tardy if he incurs tardiness, regardless of the number of minutes, ten
(10) times a month for at least two (2) months in a semester or at least two (2) consecutive
months during the year.

The OAS concluded that the concerned employees had incurred habitual tardiness
and that their justifications were unacceptable.

Issue:

Whether or Not the OAS erred in ruling that the employees were guilty of habitual
tardiness.

Held:

No. It is a canon under the Constitution that a public office is a public trust. 3 This
canon includes the mandate for the observance of prescribed office hours and the efficient
use of every moment of such hours for the public service, because only thereby may the
public servants recompense the Government and the people for shouldering the costs of
maintaining the Judiciary.4 Accordingly, court officials and employees must at all times
strictly observe official hours to inspire the publics respect for the justice system. There is
no question that all the concerned employees incurred habitual tardiness within the context
of CSC Memorandum Circular No. 04, Series of 1991, supra. Thereby, they fell short of the
standard of conduct demanded from everyone connected with the administration of justice.
Worthy of stress is that the nature and functions of the employment of the officials and
employees of the Judiciary require them to be role models in the faithful observance of the
constitutional canon that public office is a public trust. They are always accountable to the
people, whom they must serve with utmost responsibility, integrity, loyalty, and efficiency.
Absenteeism and tardiness are, therefore, impermissible. The respective justifications of the
concerned employees) are not unacceptable. If at all, such justifications may only mitigate
liability.