GR 191411; (July, 2013) (Digest)
G.R. No. 191411 and G.R. No. 191871; July 15, 2013
RAFAEL L. COSCOLLUELA, Petitioner, vs. SANDIGANBAYAN (FIRST DIVISION) and PEOPLE OF THE PHILIPPINES, Respondents. EDWIN N. NACIONALES, ERNESTO P. MALVAS, and JOSE MA. G. AMUGOD, Petitioners, vs. SANDIGANBAYAN (FIRST DIVISION) and PEOPLE OF THE PHILIPPINES, Respondents.
FACTS
Petitioners, former officials of Negros Occidental, were charged with graft for an anomalous equipment purchase. The Office of the Ombudsman received a complaint on November 9, 2001. The Graft Investigation Officer completed a Resolution and Information finding probable cause on March 27, 2003. However, the Information only received final approval from the Acting Ombudsman on May 21, 2009, and was filed with the Sandiganbayan on June 19, 2009. Petitioners claimed they only learned of the 2003 Resolution upon receiving the filed Information.
Petitioners moved to quash the Information, arguing a violation of their constitutional right to speedy disposition of cases due to an eight-year delay from complaint to filing. The Sandiganbayan denied the motion, compartmentalizing the delay. It held the preliminary investigation was resolved within a reasonable period (by March 2003), and the subsequent six-year period for review and approval was not inordinate, attributing it to internal procedural review.
ISSUE
Whether the Sandiganbayan gravely abused its discretion in ruling that petitioners’ right to speedy disposition of cases was not violated.
RULING
Yes, the Sandiganbayan committed grave abuse of discretion. The Supreme Court applied the balancing test, weighing: (1) the length of delay, (2) the reason for the delay, (3) the defendant’s assertion of the right, and (4) prejudice to the defendant. The total delay of over seven years and seven months was prima facie inordinate. The justification offered—internal review and revision—was insufficient. The Ombudsman failed to explain the specific causes for the six-year hiatus between the investigator’s recommendation and the Acting Ombudsman’s approval, rendering the delay oppressive and violative of procedural due process.
The Court rejected the Sandiganbayan’s compartmentalization of the periods. The right to speedy disposition encompasses the entire proceeding, from the filing of the complaint until its termination, including the period of review. Petitioners asserted their right promptly upon learning of the charges. Furthermore, the prolonged anxiety and the threat to public service careers constituted prejudice. Consequently, the criminal case against petitioners was dismissed for violation of their constitutional right to a speedy disposition of cases.