Marcos v. Sandiganbayan
G.R. No. 115132-34, August 9, 1995
FACTS
The petitioner, claiming that her health condition requires medical attention abroad, filed several motions for travel abroad which the Sandiganbayan denied. Because of this, the petitioner filed for certiorari to set aside the resolutions of the Sandiganbayan on the ground that they were issued with grave abuse of discretion, amounting to lack or excess of jurisdiction. The Supreme Court dismissed the petition without prejudice to the filing of another motion to travel abroad based on her heart condition. The determination of her medical condition should be made by a panel of medical specialists recommended by both the accused and the prosecution.
ISSUES
Whether or not the Sandiganbayan gravely abused its discretion in denying the petitioner’s request to travel abroad for medical treatment.
Whether or not the respondent court arbitrarily disregarded the findings and recommendations of the petitioner’s physician.
Whether or not the respondent court trifled with petitioner’s constitutionally guaranteed right to life, health and liberty.
HELD
After due consideration, the Supreme Court found that the Sandiganbayan did not gravely abuse its discretion. The respondent court had to seek expert opinion considering that the subject lay beyond its competence. It also couldn’t be expected to just accept the opinion of the petitioner’s physician. The request depended on the verification of the claim that the petitioner was suffering from a life-threatening medical condition; hence, the SC believed that the respondent court followed the only prudent course available which was seeking the opinion of other specialists in the field of medicine.
On the second issue, the respondent court did not disregard the findings and recommendations of petitioner’s physician. This was not warranted by the petitioner’s claim that the court did not personally examine her and for that reason their opinion is allegedly academic. The question raised by the petitioner’s motion was not whether the petitioner was suffering from a serious and life threatening medical condition, but whether on the basis of reports attached to the motions for travel, there was evidence to show that she was suffering from such ailments (i.e., coronary artery disease and labile hypertension) and there was need for diagnostic tests which could only be performed abroad.
On the last issue, the petitioner could not say that the respondent court trifled with petitioner’s constitution right to life, health and liberty. The later conviction in two cases dictated the need for greater caution. A person’s right to travel is subject to the usual constraints imposed by the very necessity of safeguarding the system of justice. Whether the accused should be permitted to leave the jurisdiction for humanitarian reason is a matter of the court’s sound discretion.