G.R. No. 244649, June 14, 2021
CARMENCITA C. DAEP, AMEIFE L. LACBAIN, ARNOLD B. CALCIÑA, AND ERNESTO M. MILLENA, PETITIONERS, VS. SANDIGANBAYAN – FOURTH DIVISION AND PEOPLE OF THE PHILIPPINES, RESPONDENTS.

FACTS

On August 3, 2016, an Information was filed before the Sandiganbayan charging petitioners, public officials of the Municipality of Manito, Albay, with violation of Section 3(e) of R.A. No. 3019. The charge stemmed from the alleged anomalous award of a contract for liquid fertilizer to Hexaphil Agriventures, Inc. in March to April 2004. Petitioners filed an Urgent Motion for Judicial Determination of Probable Cause on August 16, 2016, arguing, among others, that there was inordinate delay in the filing of the case, violating their right to speedy disposition of cases. They noted the complaint was filed on May 16, 2011, they filed counter-affidavits on September 12, 2011, but the Ombudsman’s Resolution was issued only on October 22, 2014. The Sandiganbayan denied this motion on February 1, 2017, finding probable cause and no inordinate delay, a ruling reiterated in a Resolution dated April 6, 2018. Petitioners filed a Motion to Dismiss on June 14, 2018, again raising the issue of inordinate delay, noting the facts arose in 2004, the complaint was filed in 2011, and the Information in 2016. The Sandiganbayan denied this motion on October 16, 2018, and denied reconsideration on November 27, 2018, prompting the petitioners to file the present Petition for Certiorari.

ISSUE

Whether or not petitioners’ constitutional right to speedy disposition of cases was violated.

RULING

No. The Supreme Court denied the petition, finding no grave abuse of discretion by the Sandiganbayan. The Court held that the right to speedy disposition of cases is relative and flexible, and is violated only by inordinate delay. Applying the guidelines from Cagang v. Sandiganbayan, the Court balanced the factors: (1) the length of delay was not presumptively prejudicial; (2) the delay was justified as the case was complex, involving voluminous documents and being part of the larger “Fertilizer Fund” scam investigations; (3) petitioners only asserted their right after the Information was filed; and (4) petitioners’ claim of prejudice (unavailable witnesses and documents) was self-serving and unsubstantiated. The Court emphasized that a mere mathematical reckoning of time is insufficient, and the prosecution’s heavy caseload and the complexity of the case justified the period taken for preliminary investigation. Thus, no violation of the right to speedy disposition occurred.