G.R. No. 229656 , August 19, 2019
People of the Philippines, Petitioner, vs. Hon. Sandiganbayan (First Division), Manuel M. Lapid, Ma. Victoria M. Aquino-Abubakar, Leolita M. Aquino and Dexter Alexander S.D. Vasquez, Respondents.

FACTS

The case stems from the “P728 Million Fertilizer Scam.” In 2004, the Provincial Government of Pampanga, under then-Governor Manuel M. Lapid, purchased overpriced fertilizers from Malayan Pacific Trading Corporation (MPTC) without public bidding. The Field Investigation Office of the Ombudsman began a fact-finding investigation in 2006. A formal complaint was filed with the Ombudsman on May 2, 2011. After respondents filed their counter-affidavits, the Ombudsman’s Special Panel found probable cause against Lapid and private respondents on September 18, 2013. Ombudsman Conchita Carpio Morales approved the resolution on June 3, 2014. An Information for violation of the Anti-Graft and Corrupt Practices Act was finally filed with the Sandiganbayan on November 4, 2015.
Prior to arraignment, Lapid moved to dismiss the case, arguing inordinate delay violated his constitutional right to a speedy disposition of cases. He counted an eight-year delay from the 2006 fact-finding start to the 2014 Ombudsman approval. The Sandiganbayan granted the motion and dismissed the case, finding the delay presumptively prejudicial and unjustified. The prosecution’s petition for certiorari argued the Sandiganbayan committed grave abuse of discretion.

ISSUE

Did the Sandiganbayan commit grave abuse of discretion in dismissing the criminal case on the ground of inordinate delay, thereby violating the respondents’ right to a speedy disposition of cases?

RULING

No, the Sandiganbayan did not commit grave abuse of discretion. The Supreme Court, applying the comprehensive guidelines in Cagang v. Sandiganbayan, held that the right to a speedy disposition of cases covers periods before and after the filing of a formal complaint. The Court examined the timeline: a fact-finding investigation started in 2006, a complaint was filed in 2011, a resolution finding probable cause was issued in 2013, approved in 2014, and the Information was filed in 2015. The Court found the delay, particularly the three-year period from the 2011 complaint to the 2014 approval, was inordinate and unexplained by the complexity of the case or the actions of the accused.
The legal logic is that the constitutional right is violated when the proceeding is attended by vexatious, capricious, and oppressive delays. The burden to justify the delay shifts to the prosecution once the accused proves the delay was lengthy and that they invoked their right seasonably, which Lapid did before arraignment. Here, the prosecution failed to provide a credible, compelling reason for the protracted preliminary investigation. The Sandiganbayan’s factual finding of inordinate delay, being supported by the record, was not reached arbitrarily and thus deserved respect. The petition was denied, and the dismissal of the criminal case was affirmed.