GR 174902; (February, 2008) (Digest)
G.R. Nos. 174902-06; February 15, 2008
ALFREDO R. ENRIQUEZ, GENER C. ENDONA, and RHANDOLFO B. AMANSEC, petitioners, vs. OFFICE OF THE OMBUDSMAN, respondent.
FACTS
The Fact-Finding and Intelligence Bureau (FFIB) of the Office of the Ombudsman filed administrative and criminal complaints against petitioners Alfredo R. Enriquez, Gener C. Endona, and Rhandolfo B. Amansec, among others, on May 9, 2000. The charges stemmed from the Land Registration Authority’s Land Titling Computerization Project bidding. Petitioners submitted their Joint Counter-Affidavit, and after hearings, both parties formally offered their evidence by January 29, 2002. Despite the completion of evidentiary submissions, the Ombudsman took no action. Petitioners filed a Motion to Set Date for Memoranda in July 2002 and a co-respondent filed a Motion for Early Resolution in December 2002, but the Ombudsman remained inactive.
On March 24, 2006, petitioners moved to dismiss the cases, arguing that the Ombudsman’s inordinate delay of over six years from filing and more than four years after the formal offer of evidence violated their constitutional right to a speedy disposition of cases. They claimed this delay caused severe anxiety, reputational damage, and denial of employment and retirement benefits. The FFIB did not oppose the motion, yet the cases remained unresolved, prompting petitioners to file this petition for mandamus in October 2006.
ISSUE
The issues are: (1) whether a petition for mandamus is an appropriate remedy to compel the Ombudsman to act, and (2) whether the Ombudsman violated petitioners’ constitutional right to a speedy disposition of their cases.
RULING
The Supreme Court granted the petition. On the first issue, mandamus is appropriate. While mandamus typically compels ministerial duties, it can issue to control discretion when there is grave abuse of discretion, such as an unjustified failure to act that violates a constitutional right. The Ombudsman’s prolonged inaction here constituted such an abuse, making mandamus a proper remedy to enforce petitioners’ right to a speedy disposition.
On the second issue, the Court ruled that the Ombudsman violated petitioners’ right to a speedy disposition of cases under Section 16, Article III of the Constitution . The right applies to all cases before judicial, quasi-judicial, or administrative bodies. The delay of over six years, with no resolution more than four years after the formal offer of evidence, was presumptively prejudicial. The Ombudsman’s claim that prosecutors were exercising “extreme care” was insufficient justification, as the period far exceeded its own rules mandating resolution within thirty days after submission. The delay was vexatious and oppressive, causing petitioners real prejudice. Consequently, the administrative and criminal cases against petitioners were ordered dismissed.