G.R. No. 242892 . July 06, 2022
APOLINARIO T. CAMSOL, ANECITA C. SUYAT, MARCELINO ENDI, AND ASANO E. ABAN, PETITIONERS, VS. SEVENTH DIVISION OF THE SANDIGANBAYAN, HEADED BY ITS CHAIRPERSON, ASSOCIATE JUSTICE MA. THERESA DOLORES C. GOMEZ-ESTOESTA, AND DIVISION MEMBER ASSOCIATE JUSTICE GEORGINA D. HIDALGO AND ASSOCIATE JUSTICE ZALDY V. TRESPESES, RESPONDENTS.

FACTS

Petitioners, former municipal officials of Buguias, Benguet, were charged with violation of Section 3(e) of R.A. 3019 in relation to the Fertilizer Fund Scam. The case stemmed from a 2004 transaction involving the procurement of farm supplies worth over P1 million without public bidding. The Commission on Audit issued a Notice of Disallowance on June 23, 2006. A complaint was filed with the Office of the Ombudsman on July 1, 2011. After preliminary investigation, the Ombudsman issued a Resolution finding probable cause on November 10, 2015. An Information was finally filed with the Sandiganbayan on April 20, 2018. Before arraignment, petitioners moved to dismiss the case based on inordinate delay, arguing that approximately six years elapsed from the filing of the complaint to the filing of the Information, violating their constitutional right to speedy disposition of cases.
The Sandiganbayan denied the motion to dismiss and the subsequent motion for reconsideration, ruling that the delay was not inordinate and unjustified. The anti-graft court held that petitioners failed to consider the other factors in the balancing test for inordinate delay, focusing only on the length of time. Aggrieved, petitioners filed the instant Petition for Certiorari, Prohibition, and Mandamus, asserting that the Sandiganbayan committed grave abuse of discretion in not dismissing the case.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion in denying the motion to dismiss despite an inordinate delay of approximately six years from the filing of the complaint to the filing of the Information, which violated petitioners’ right to speedy disposition of cases.

RULING

Yes. The Supreme Court granted the petition, annulled the Sandiganbayan’s resolutions, and ordered the dismissal of the criminal case. The Court applied the guidelines in Cagang v. Sandiganbayan, which require a factual determination of inordinate delay using a balancing test of four factors: (1) the length of delay, (2) the reasons for the delay, (3) the defendant’s assertion of the right, and (4) prejudice to the defendant. The Court found the delay of about six years from complaint to Information filing to be prima facie inordinate, shifting the burden to the prosecution to justify the delay.
The prosecution failed to provide a valid, compelling reason for the protracted period. The Court noted the case was not complex, involving a straightforward transaction. The Ombudsman’s claim of a heavy workload was deemed insufficient justification, as it is a constant reality that must be managed without infringing constitutional rights. On the assertion of the right, petitioners timely raised the issue via a motion to dismiss before arraignment, which cannot be construed as acquiescence. Finally, the prejudice to petitioners was evident, as the prolonged anxiety and threat of prosecution impaired their right to refute accusations promptly. Consequently, the Sandiganbayan’s failure to uphold this constitutional right constituted grave abuse of discretion warranting the dismissal of the case.