GR 236177 210; (February, 2021) (Digest)
G.R. No. 236177 -210, February 3, 2021
Joan V. Alarilla, Petitioner, vs. The Honorable Sandiganbayan (Fourth Division) and the People of the Philippines, Respondents.
FACTS
Petitioner Joan V. Alarilla was the elected city mayor of Meycauayan, Bulacan. On January 18, 2008, a complaint for malversation through falsification and violations of the Anti-Graft and Corrupt Practices Act was filed against her and her husband before the Office of the Ombudsman. The Ombudsman directed them to file counter-affidavits on May 7, 2008, which they filed on July 9, 2008. Petitioner’s husband died on March 4, 2009. The Ombudsman issued a Resolution finding probable cause against petitioner only on November 3, 2016, which she received on March 7, 2017—almost nine years after the complaint was filed. Petitioner filed a motion for reconsideration and a supplemental motion, asserting a violation of her right to speedy disposition of cases. The Ombudsman denied the motion. Subsequently, Informations were filed with the Sandiganbayan. Petitioner filed an Omnibus Motion before the Sandiganbayan seeking dismissal on the ground of inordinate delay, which the Sandiganbayan denied. Her motion for reconsideration was also denied.
ISSUE
Whether or not the Sandiganbayan acted with grave abuse of discretion in ruling that petitioner’s constitutional right to speedy disposition of cases was not violated.
RULING
Yes. The Supreme Court granted the petition, annulled the Sandiganbayan’s Resolutions, and ordered the dismissal of the criminal cases. The Court found that the Ombudsman incurred an inordinate delay of almost nine years in concluding the preliminary investigation without sufficient justification. Applying the guidelines in Cagang v. Sandiganbayan, the Court held that the delay was beyond the reasonable periods contemplated under the Rules of Court, which apply suppletorily. The prosecution failed to discharge its burden of proving that the delay was justified, as it did not show the complexity of the issues, the volume of evidence, or that it followed prescribed procedures. The Court also found that petitioner timely asserted her right through her supplemental motion for reconsideration before the Ombudsman and her Omnibus Motion before the Sandiganbayan prior to arraignment, and did not waive such right. The Sandiganbayan’s refusal to uphold this right constituted grave abuse of discretion.