GR 101302; (January, 1995) (Digest)
G.R. No. 101302 January 25, 1995
Jaime C. Dacanay, petitioner, vs. People of the Philippines and the Honorable Sandiganbayan, respondents.
FACTS
Petitioner Jaime C. Dacanay, former vice-president of the National Sugar Trading Corporation (NASUTRA), was charged before the Sandiganbayan in 1986 for violation of the Anti-Graft and Corrupt Practices Act concerning sugar importations in 1983-1984. After the filing of the information, the case saw protracted proceedings, including a prosecutorial recommendation for dismissal that was later disapproved by the Ombudsman. The Sandiganbayan denied motions to quash filed by Dacanay and a co-accused.
In 1991, Dacanay filed a motion for immediate and separate trial, invoking his constitutional right to a speedy trial. The prosecution opposed, arguing a separate trial would cause lengthy and repetitious proceedings since the principal accused was abroad and not yet arrested. The Sandiganbayan denied Dacanay’s motion and subsequent motion for reconsideration, prompting this petition.
ISSUE
Whether petitioner Dacanay is entitled to a separate trial to vindicate his constitutional right to a speedy trial.
RULING
Yes. The Supreme Court granted the petition, ordering the Sandiganbayan to proceed with Dacanay’s trial, separately if necessary. The Court anchored its decision on Section 8, Rule 119 of the 1985 Rules on Criminal Procedure, which allows separate trials at the court’s discretion. While joint trials are generally preferred to avoid repetitious presentation of evidence, this procedural convenience cannot override the fundamental constitutional right to a speedy trial.
The Court emphasized that the prosecution’s opposition, based on the absence of the principal accused, actually strengthened Dacanay’s plea. An accused who is available and under the court’s jurisdiction should not be made to wait indefinitely for a trial because a co-accused remains at large. Furthermore, by the time of the Court’s decision, the principal accused had returned and entered into a compromise, making the further delay of Dacanay’s trial even less justifiable. The eight-year delay since the filing of the information, coupled with Dacanay’s advanced age (over 73), constituted a clear prejudice that the right to a speedy trial seeks to prevent. The right is designed to avoid oppressive delays and require courts to proceed with reasonable dispatch.