G.R. No. 205963 -64, July 7, 2016
Amando A. Inocentes, Petitioner, vs. People of the Philippines, et al., Respondents.

FACTS

Petitioner Amando A. Inocentes, a GSIS Branch Manager, was charged before the Sandiganbayan with two counts of violating Section 3(e) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act). The informations alleged that in 2001, he conspired with others to approve housing loans for unqualified borrowers and for a commercial project, causing undue injury to the government. After the Sandiganbayan found probable cause and issued warrants, Inocentes posted bail and filed an omnibus motion to quash the informations and dismiss the case. He argued the informations were defective, the Sandiganbayan lacked jurisdiction as his Salary Grade was 26, and his right to speedy disposition was violated due to a seven-year delay from the complaint’s filing to the information’s filing.
The Sandiganbayan denied his motion, holding it had jurisdiction under P.D. 1606 as amended, which includes managers of GOCCs regardless of salary grade for R.A. 3019 violations. It also ruled the informations sufficiently alleged the elements of the offense and that the delay was excusable due to the transfer of case records. Inocentes filed a motion for reconsideration, which was also denied, prompting this petition for certiorari.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion in denying Inocentes’ motion to dismiss based on the alleged violation of his constitutional right to a speedy disposition of his case.

RULING

Yes. The Supreme Court granted the petition and ordered the dismissal of the criminal cases. The Court emphasized that the right to a speedy disposition of cases is a fundamental right guaranteed by the Constitution, applicable to all judicial and quasi-judicial proceedings, including preliminary investigations by the Ombudsman. To determine if this right was violated, the Court applied the balancing test from Barker v. Wingo, weighing: (1) the length of delay; (2) the reason for the delay; (3) the defendant’s assertion of his right; and (4) prejudice to the defendant.
Here, the delay of approximately seven years from the filing of the complaint in 2005 to the filing of the informations in 2012 was prima facie inordinate. The Ombudsman failed to provide a justifiable reason for this protracted delay, merely citing the complexity of the case and the transfer of records, which the Court found insufficient. Inocentes had timely asserted his right in his omnibus motion before the Sandiganbayan. Furthermore, the prolonged anxiety and public suspicion borne by Inocentes, who was a public official, constituted undeniable prejudice. The Court concluded that the Ombudsman gravely abused its discretion in not resolving the case within a reasonable time, thereby violating Inocentes’ constitutional right. Consequently, the Sandiganbayan’s resolutions were reversed and the cases were ordered dismissed.