The Sandiganbayan 5th Division has granted former Department of Public Works and Highways (DPWH) secretary Manuel Bonoan’s request for hospital arrest. The resolution, made public on Friday, June 5, allows the 80-year-old former official to be confined at the Philippine National Police (PNP) General Hospital in Camp Crame, Quezon City, while his plunder and graft cases remain pending.
5th Division Chairperson Associate Justice Zaldy Trespeses, along with Associate Justices Maryann Corpus Mañalac and Gener Gito, signed the ruling. The court determined that when life-threatening conditions are present, the right to health and life must prevail over mandatory detention, noting that the court “cannot turn a blind eye to humanitarian exigencies that present a clear and present danger to his life.”
Medical and Legal Context
Bonoan’s motion highlighted a series of serious health concerns, including stage 4 chronic renal disease, hypertension, diabetes, gouty arthritis, spondylolisthesis, dyslipidemia and prostate cancer. Department of the Interior and Local Government chief Juanito Victor “Jonvic” Remulla noted that the move is a temporary measure and confirmed that Bonoan underwent two procedures this week to treat a heart attack.

The court drew a parallel to the Enrile v. Sandiganbayan case, where the Supreme Court previously granted bail on humanitarian grounds. The 5th Division reasoned that if full provisional liberty is permissible for an elderly or ill accused on such grounds, then hospital arrest—which is more restrictive and highly monitored—is a logical and legally permissible alternative.
Did You Know? The court specifically cited Manuel Bonoan’s return to the country in January to cooperate with the Senate blue ribbon committee, alongside his surrender to the Sandiganbayan 2nd Division on May 29, as evidence of his respect for legal processes.
Expert Insight: This ruling underscores the ongoing legal tension between the state’s duty to enforce detention for serious charges like plunder and the judiciary’s obligation to uphold the constitutional right to health for elderly defendants. By opting for hospital arrest rather than full bail, the court is attempting to balance the security of the prosecution with humanitarian mandates.
Implications and Future Proceedings
Bonoan faces plunder and graft charges in the 5th Division, as well as a separate graft case in the 2nd Division related to alleged flood control insertions. His co-accused in the 2nd Division include Senator Jinggoy Estrada and other DPWH officials.

Due to his current medical condition, Bonoan has yet to be arraigned in either division. It is expected that the court will continue to monitor his health status, and a formal medical diagnosis is slated to be submitted to the Sandiganbayan. As the case moves forward, the prosecution’s concerns regarding the sufficiency of his medical justifications may remain a point of contention during future hearings.
Frequently Asked Questions
What are the charges against Manuel Bonoan?
Bonoan faces plunder and graft cases in the Sandiganbayan 5th Division, and an additional count of graft in the 2nd Division regarding alleged involvement in flood control insertions.
Why was the request for hospital arrest granted?
The 5th Division ruled that Bonoan’s life-threatening medical conditions—which include stage 4 chronic renal disease and prostate cancer—require constant special medical attention, and that his right to life and health takes precedence over mandatory detention.
Has Bonoan been arraigned yet?
No, Bonoan has not been arraigned by either the 2nd or the 5th Division due to his current medical condition.
How do you believe the judiciary should balance humanitarian concerns against the gravity of public corruption charges?
