GR 140863; (August, 2000) (Digest)
G.R. No. 140863 ; August 22, 2000
SOLAR TEAM ENTERTAINMENT, INC. and PEOPLE OF THE PHILIPPINES, petitioners, vs. HON. ROLANDO HOW, in his capacity as Presiding Judge of the Regional Trial Court Branch 257 of Parañaque and MA. FE F. BARREIRO, respondents.
FACTS
An Information for estafa was filed against private respondent Ma. Fe Barreiro before the Regional Trial Court. Prior to her scheduled arraignment, she filed a petition for review with the Secretary of Justice (SOJ). The trial court, presided by respondent Judge Rolando How, issued orders deferring the arraignment, initially to a later date and subsequently “until such time that the appeal with the said office (SOJ) is resolved.” Petitioner Solar Team Entertainment, Inc. moved for reconsideration, arguing that the indefinite suspension violated the 30-day limit for arraignment under Section 7 of the Speedy Trial Act of 1998 (R.A. 8493) and Section 12, Rule 116 of the Revised Rules on Criminal Procedure. The trial court denied the motion.
ISSUE
Whether the trial court committed grave abuse of discretion in indefinitely suspending the arraignment of the accused pending the resolution of her petition for review with the Secretary of Justice.
RULING
The Supreme Court ruled that the trial court did not commit grave abuse of discretion. The legal logic is anchored on the established power of control and supervision of the Secretary of Justice over prosecutors, which includes the authority to review, reverse, or modify their resolutions. This power persists even after an information is filed in court. The Court, citing precedents like Marcelo v. Court of Appeals and Ledesma v. Court of Appeals, clarified that the ruling in Crespo v. Mogul—which emphasizes the court’s authority over the disposition of the case once filed—does not divest the Secretary of Justice of this review authority. Consequently, a prudent deferment of arraignment to await the SOJ’s resolution is a valid exercise of judicial discretion to avoid potential conflicts and multiplicity of proceedings. It prevents a scenario where an accused is arraigned only for the information to be later withdrawn upon a reversal by the SOJ. The 30-day period under the Speedy Trial Act is not absolute and can yield to special circumstances, such as a pending DOJ review, to serve the higher interest of justice. The Court found the suspension reasonable and not indefinite, as the DOJ review process has its own timelines, and the delay was not attributable to the accused.