Juan Ponce Enrile v. People of the Philippines
The Office of the Ombudsman filed an Information for plunder against Enrile, Jessica Lucila Reyes, Janet Lim Napoles, Ronald John Lim, and John Raymund de Asis before the Sandiganbayan.
In 2004 to 2010 or thereabout, in the Philippines, and within this Honorable Court’s jurisdiction, above-named accused JUAN PONCE ENRILE, then a Philippine Senator, et al. did then and there willfully, unlawfully, and criminally amass, accumulate, and/or acquire ill-gotten wealth amounting to at least ONE HUNDRED SEVENTY TWO MILLION EIGHT HUNDRED THIRTY FOUR THOUSAND FIVE HUNDRED PESOS (Php172,834,500.00) through a combination or series of overt criminal acts
Enrile filed a motion for bill of particulars before the Sandiganbayan. On the same date, he filed a motion for deferment of arraignment since he was to undergo medical examination at the Philippine General Hospital (PGH).
The Court denied Enrile’s motion for bill of particulars.
Is a Motion to Quash the proper remedy if the information is vague or indefinite resulting in the serious violation of Enrile’s constitutional right to be informed of the nature and cause of the accusation against him.
NO. When allegations in an Information are vague or indefinite, the remedy of the accused is not a motion to quash, but a motion for a bill of particulars.
The purpose of a bill of particulars is to supply vague facts or allegations in the complaint or information to enable the accused to properly plead and prepare for trial. It presupposes a valid Information, one that presents all the elements of the crime charged, albeit under vague terms. Notably, the specifications that a bill of particulars may supply are only formal amendments to the complaint or Information. Thus, if the Information is lacking, a court should take a liberal attitude towards its granting and order the government to file a bill of particulars elaborating on the charges. Doubts should be resolved in favor of granting the bill to give full meaning to the accused’s Constitutionally guaranteed rights.