GR 241257; (September, 2020) (Digest)
G.R. No. 241257 , September 29, 2020
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. BRENDO P. PAGAL, ACCUSED-APPELLANT.
FACTS
Accused-appellant Brendo P. Pagal was charged with Murder. During his arraignment on August 20, 2009, he pleaded guilty. In accordance with Section 3, Rule 116 of the Revised Rules of Criminal Procedure, which mandates the presentation of evidence to determine the precise degree of culpability despite a guilty plea to a capital offense, the Regional Trial Court (RTC) ordered the prosecution to present its evidence. The prosecution, however, repeatedly failed to present its witnesses over multiple scheduled hearings from 2010 to 2011, despite the proper issuance and service of subpoenas.
Consequently, with no evidence presented by the prosecution and with the defense also opting not to present evidence, the RTC proceeded to render a judgment based solely on the plea of guilty. It found Pagal guilty beyond reasonable doubt of Murder and sentenced him to reclusion perpetua. On appeal, the Court of Appeals (CA) annulled the RTC Order and remanded the case for further proceedings, without ruling on the merits.
ISSUE
Whether the Court of Appeals erred in remanding the case to the trial court for further proceedings instead of dismissing the case on the ground of the prosecution’s failure to present evidence, which violates the accused’s constitutional right to a speedy disposition of his case.
RULING
The Supreme Court, speaking through Justice Gesmundo, REVERSED the CA decision and ordered the DISMISSAL of the criminal case against Pagal. The Court held that the remand would violate the accused’s right to a speedy disposition of cases. The legal logic is anchored on a balancing test, weighing the conduct of both the prosecution and the accused against the prejudice caused by the delay.
The prosecution’s unjustified failure to present its witnesses for nearly two years, despite the court’s directives and proper subpoenas, constituted inordinate delay. This delay was solely attributable to the State. In contrast, Pagal’s conduct demonstrated a desire for a speedy conclusion; he pleaded guilty at arraignment and did not cause any postponements. The prejudice to Pagal is manifest. A remand for a full-blown trial, over a decade after the crime and after the prosecution’s earlier default, would force him to defend against a stale charge, undermining the fairness the right to speedy disposition seeks to protect. The State’s right to prosecute cannot prevail over the constitutional right of the accused when such protracted and unjustified delay has occurred. Therefore, the case must be dismissed.