G.R. No. 238877 , March 22, 2023.
PEOPLE OF THE PHILIPPINES, PETITIONER, VS. SANDIGANBAYAN (FOURTH DIVISION), EVELIO RAMOS LEONARDIA, GOLDWYN V. NIFRAS, LUZVIMINDA S. TREYES, NELSON M. SEDILLO, SR., BELLY P. AGUILLON, EDUARDO H. RAVENA, ALADINO A. AGBONES, JARIES EBENIZER E. ENCABO, MELVIN B. RECABAR, AND ANABELLE C. BADAJOS, RESPONDENTS.

FACTS

On October 14, 2008, a complaint was filed with the Office of the Ombudsman (Visayas) regarding alleged irregularities in the award of a furniture supply contract for the Bacolod City New Government Center to Comfac Corporation. This was docketed as CPL-V-08-0801. On May 9, 2011, an Assistant Ombudsman recommended its closure, but the matter was referred for further evaluation. On May 24, 2011, the Ombudsman received an anonymous letter on the same subject, docketed as CPL-V-11-0557. On December 6, 2012, the Ombudsman approved consolidating the two cases. On December 26, 2012, the Ombudsman approved a report recommending the investigation of the respondents for violation of Section 3(e) of R.A. No. 3019 and administrative charges. A Complaint Affidavit was filed on March 1, 2013, docketed as OMB-V-C-13-0177 and OMB-V-A-13-0186. The respondents filed various motions for extension and their counter-affidavits between September and December 2013. The Ombudsman issued a Joint Resolution on December 13, 2016, finding probable cause and administrative liability. The respondents filed motions for reconsideration, raising, among others, the issue of inordinate delay. The Ombudsman denied these motions on May 16, 2017, and September 14, 2017. An Information was filed with the Sandiganbayan on November 24, 2017. The respondents filed motions to dismiss, citing violation of their constitutional right to speedy disposition of cases. The Sandiganbayan granted the motions and dismissed the case in a Resolution dated January 26, 2018, citing inordinate delay. It denied the prosecution’s motion for reconsideration on March 1, 2018. In a separate Resolution dated April 5, 2018, it also dismissed the case against respondent Badajos for lack of jurisdiction, as she occupied a position with Salary Grade 26. The People of the Philippines filed this Petition for Certiorari.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction in dismissing the criminal case against the respondents.

RULING

No. The Supreme Court found that the Sandiganbayan did not commit grave abuse of discretion. The Court applied the four-factor test to determine if the right to speedy disposition of cases was violated: (1) the length of delay, (2) the reason for the delay, (3) the defendant’s assertion of the right, and (4) the prejudice to the defendant.
1. Length of Delay: The proceedings spanned approximately eight years and two months from the initial complaint in October 2008 until the filing of the Information in November 2017. This period was deemed presumptively prejudicial.
2. Reason for the Delay: The prosecution failed to provide a justifiable reason for the delay. The Court noted that the Ombudsman took over four years (from October 2008 to December 2012) to decide to conduct a preliminary investigation from the fact-finding stage, and another four years (from March 2013 to December 2016) to resolve the preliminary investigation. The Court found these intervals unreasonable and unjustified.
3. Assertion of the Right: The respondents timely asserted their right to speedy disposition in their motions for reconsideration before the Ombudsman in January 2017 and in their motions to dismiss before the Sandiganbayan in December 2017.
4. Prejudice to the Defendant: The prolonged anxiety and stress caused by the eight-year investigation constituted prejudice to the respondents.
The Court held that the Sandiganbayan correctly balanced these factors and did not act capriciously or whimsically in finding a violation of the right to speedy disposition. Regarding respondent Badajos, the Sandiganbayan correctly dismissed the case against her for lack of jurisdiction, as her position (Salary Grade 26) was not within the Sandiganbayan’s exclusive original jurisdiction at the time the offense was allegedly committed. The Petition was dismissed.