GR 166606; (November, 2005) (Digest)
G.R. No. 166606 November 29, 2005
GUILLERMO T. DOMONDON and VAN D. LUSPO, Petitioners, vs. HON. FIRST DIVISION, SANDIGANBAYAN, Respondent.
FACTS
Petitioners Guillermo Domondon and Van Luspo, along with other PNP officers, were charged before the Sandiganbayan with violation of the Anti-Graft and Corrupt Practices Act for allegedly conspiring to approve and release P20 million for ghost purchases of combat equipment. An Information was filed in 1994. Their arraignment was repeatedly reset over the years due to various pending incidents, including motions for reinvestigation, consolidation, a petition for certiorari to the Supreme Court filed by Domondon, motions to quash, and a motion for a bill of particulars filed by a co-accused. On December 3, 2003, petitioners filed a motion to dismiss, arguing that the failure to arraign them violated their right to a speedy trial under the Speedy Trial Act. The Sandiganbayan denied the motion, prompting this certiorari petition.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion in denying the motion to dismiss for alleged violation of the right to speedy trial.
RULING
The Supreme Court ruled that the Sandiganbayan did not commit grave abuse of discretion. The right to a speedy trial is relative and must be balanced with the state’s duty to prosecute crimes. The Court applied the four-factor test: length of delay, reason for delay, the defendant’s assertion of the right, and prejudice to the defendant. While the period from filing in 1994 to the motion in 2003 was lengthy, the delays were not attributable to the prosecution’s inordinate or oppressive actions. The postponements were largely due to numerous pending motions and petitions filed by the petitioners themselves and their co-accused, including Domondon’s petition to the Supreme Court, which necessarily suspended proceedings. The Court emphasized that delays caused by the resolution of such procedural incidents, undertaken to ensure due process for all parties, cannot be deemed vexatious. Petitioners could not claim prejudice from delays they substantially contributed to, nor could they selectively disassociate themselves from delays caused by a co-accused’s motions while benefiting from their own. Consequently, no violation of the right to speedy trial occurred, and the denial of the motion to dismiss was proper.