CASE DIGEST
Figueroa v.
Sandiganbayan, Special Third Division
G.R. Nos. 235965-66, [February 15, 2022]
FIRST, LOPEZ, M.V
Inordinate Delay;
Speedy Disposition of cases
An accused has no duty to bring himself to trial. The accused must be spared from the rigors and expense of a full-blown trial where it is clear that inordinate and vexatious delays crept the conduct of preliminary investigation which are violative of the constitutional guarantee to speedy disposition of cases.
The Philippine Amusement and Gaming Corporation (PAGCOR) lodged a corruption complaint against Rene Figueroa and other officers, initiating a preliminary investigation on July 19, 2011. By July 29 of the same year, the Office of the Ombudsman directed Rene and his co-accused to submit their counter-affidavits within ten days. Subsequently, on August 16, 2011 Rene requested an extension of ten additional days to file his counter-affidavit, which was granted. He submitted his counter-affidavit on September 5,2011. The Ombudsman recommended filing charges against Rene and others for violation of Sections 3(e) of Republic Act No. 3019 on September 22, 2014. Charges were filed before the Sandiganbayan on June 3, 2016, and the amended informations were admitted on July 4, 2017. Rene moved to quash the informations on July 20, 2017, citing undue delay in case handling, as more than six years had passed since the complaint was filed without a decision on the charges to be filed. However, the Sandiganbayan denied the motion to quash.
Whether or not the Sandiganbayan acted
with grave abuse of discretion amounting to lack or excess of jurisdiction in
denying Rene's motion to quash the informations.
YES. The Sandiganbayan acted with grave abuse of
discretion in denying the motion to quash.
Article III, Section 16 of the 1987 Constitution
safeguards individuals' entitlement to a speedy disposition of cases in all
judicial, quasi-judicial, or administrative bodies. Cagang v. Sandiganbayan
delineates the approach for assessing claims related to the right to speedy
disposition of cases or speedy trial. The right to speedy trial applies only to
criminal prosecutions before courts of law, while the right to speedy
disposition of cases applies to any tribunal, judicial or quasi-judicial. Notably,
the period for fact-finding investigations before filing formal complaints is
not counted in determining delays. As such, investigations preceding the filing
of formal complaints are not counted in determining delay. Analysis of delay duration is not
rigidly mechanical and must consider circumstances.
In the case at hand, the Ombudsman exceeded the
time for preliminary investigation, warranting justification for the delay.
However, the Ombudsman failed to provide sufficient explanation, merely arguing
that any delay was reasonable. While Rene did not initially assert his right,
he raised it in due time before the Sandiganbayan's ruling on the amended
informations, sufficient to invoke constitutional protection against undue
delay.
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