GR 145851; (November, 2001) (Digest)
G.R. No. 145851; November 22, 2001
ABELARDO B. LICAROS, petitioner, vs. THE SANDIGANBAYAN and THE SPECIAL PROSECUTOR, respondents.
FACTS
Petitioner Abelardo B. Licaros was charged as an accessory after the fact in a 1982 bank robbery case. The prosecution’s own evidence showed that it was Licaros who reported his suspicions to Central Bank officials, leading to the recovery of stolen money and the arrest of the principal accused. He was arraigned in 1982, and the prosecution formally rested its case in 1984. Despite this, the Sandiganbayan failed to render a decision for over ten years after the case was submitted for resolution. Licaros filed multiple motions, including a motion to dismiss based on the right to speedy disposition, and a petition for mandamus, all of which remained unresolved by the anti-graft court.
ISSUE
Whether the Sandiganbayan’s failure to decide the criminal case against Licaros for more than ten years after submission for resolution constitutes a violation of his constitutional right to speedy disposition of cases, warranting dismissal.
RULING
Yes. The Supreme Court granted the petition for mandamus and ordered the dismissal of the criminal case. The Court emphasized that the constitutional right to the speedy disposition of cases applies not only during trial but also when a case has been submitted for decision. An unreasonable delay violates this right. The Court applied a balancing test, weighing the conduct of both the prosecution and the accused. Here, the delay of over a decade was inordinate and inexcusable, attributable solely to the Sandiganbayan’s inaction. Licaros, meanwhile, was not at fault; he consistently asserted his right and pursued legal avenues to obtain a resolution. The Court found that the prolonged anxiety and oppression suffered by the petitioner, coupled with the absence of any reasonable justification for the delay, outweighed any government interest in proceeding with the prosecution. Consequently, the case was dismissed to uphold the constitutional guarantee of speedy disposition.