Marcos v. Sandiganbayan
REITERATIONFacts
The Antecedents: Petitioner Imelda R. Marcos, convicted in two criminal cases for violations of the Anti-Graft and Corrupt Practices Act (R.A. No. 3019), filed motions for leave to travel abroad for medical treatment, citing serious and life-threatening medical conditions not available in the Philippines. These motions were filed in various criminal cases pending before the Sandiganbayan. Procedural History: The Sandiganbayan initially denied a motion for failure to notify the prosecution and due to the proximity of the requested travel dates. Subsequently, petitioner filed further motions, supported by medical reports from her physicians. The Sandiganbayan, through its Presiding Justice, sought expert opinions from the Philippine Heart Center and formed a committee of cardiologists to review the medical findings. The Presidential Commission on Good Government interposed no objection on humanitarian grounds, while the Office of the Special Prosecutor opposed the motions, citing lack of demonstrated necessity and the risk of non-return. After hearings and the presentation of evidence, including the committee's report which contradicted petitioner's physicians' conclusions, the Sandiganbayan denied the motions. A motion for reconsideration was also denied, with the court expressing disapproval of attempts to influence its decisions. The Petition: Petitioner filed a petition for certiorari before the Supreme Court, alleging that the Sandiganbayan gravely abused its discretion by arbitrarily disregarding her physicians' testimonies and findings, relying instead on academic views of experts who had not personally examined her. She also questioned the court's conduct of trial and its consideration of her conviction in pending reconsideration as a factor in denying her rights.
Issue(s)
Whether the Sandiganbayan gravely abused its discretion in denying petitioner's motions for leave to travel abroad for medical treatment. Whether the Sandiganbayan's conduct of seeking expert opinions and forming a committee violated petitioner's right to due process. Whether the Sandiganbayan erred in considering petitioner's conviction in cases pending reconsideration as a factor in denying her right to travel.
Ruling
The petition is dismissed. The Sandiganbayan did not gravely abuse its discretion in denying petitioner's motions for leave to travel abroad. The resolutions dated February 18, 1994, and April 19, 1994, are affirmed.
Ratio Decidendi
On the issue of grave abuse of discretion in denying the motion for leave to travel: The Supreme Court held that the Sandiganbayan did not gravely abuse its discretion. The court was justified in seeking expert opinions from the Philippine Heart Center because the petitioner's claim of a serious and life-threatening medical condition was based on her physician's advice, which the court could not simply accept without verification. The court's actions were prudent and aimed at obtaining a clearer understanding of the medical necessity for the travel. The court emphasized that the petitioner, facing criminal charges and having been convicted in two cases, did not possess an absolute right to leave the country and bore the burden of proving the necessity of seeking medical treatment abroad due to danger to her health or life. The evidence presented, particularly the report from the panel of experts, did not sufficiently establish this necessity. On the issue of due process and the Sandiganbayan's conduct: The Court found no violation of due process. The Sandiganbayan's procedure of seeking expert opinions was transparent, with all parties participating in the proceedings. Petitioner's counsel did not object to the court's referral of medical reports for expert review and even submitted additional questions. Furthermore, counsel actively participated in cross-examining the expert witness. The court's active role in examining witnesses and seeking clarification was deemed justified given the technical nature of the medical issues involved, citing established jurisprudence that judges are not mere referees but should actively participate in ensuring an orderly and expeditious trial. The court noted that petitioner had been permitted to travel abroad on three previous occasions, but her subsequent conviction necessitated greater caution. On the issue of considering the conviction in pending reconsideration: The Court stated that while conviction is not yet final, a person's right to travel is subject to constraints necessary for safeguarding the justice system. The Sandiganbayan's consideration of the conviction was a factor in exercising its sound discretion regarding the request for humanitarian reasons. The Court also clarified that the medical findings of petitioner's physicians were not arbitrarily disregarded but were weighed against the report of the panel of experts. The panel's findings indicated that the diagnosis of coronary artery disease was questionable, that the hypertension was transient, and that the recommended tests and expertise were available in the Philippines. The court also noted that subsequent tests performed by petitioner's own physician yielded normal results, further undermining the claim of imperative medical necessity for foreign travel.
Main Doctrine
The Sandiganbayan did not gravely abuse its discretion in denying petitioner's motion for leave to travel abroad for medical treatment, as the imperative necessity for such trip was not sufficiently established, and the court's actions in seeking expert opinions and conducting hearings were within its sound discretion and did not violate petitioner's right to due process.