G.R. Nos. 246318-19. January 18, 2023
ARTHUR CUA YAP, PETITIONER, VS. SANDIGANBAYAN (SIXTH DIVISION) AND PEOPLE OF THE PHILIPPINES, RESPONDENTS.

FACTS

Petitioner Arthur Cua Yap, former Secretary of the Department of Agriculture and ex-officio Chairman of the Philippine Rice Research Institute (PhilRice) Board of Trustees (BOT), was charged before the Sandiganbayan with violations of Section 3(e) and 3(g) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act). The charges stemmed from the PhilRice BOT’s approval of a car plan program in 2008, which was implemented via Administrative Order No. 2009-05. The program allowed employees to obtain personal loans from the Philippine National Bank (PNB) for car purchases, secured by PhilRice funds through Hold Out Agreements (HOAs), and the purchased cars were then leased by PhilRice for official use. The Office of the Ombudsman found probable cause, alleging the scheme was grossly disadvantageous to the government. Petitioner filed a Motion to Quash the Informations, arguing the facts alleged did not constitute the offenses and that there was an inordinate delay in the preliminary investigation, violating his right to speedy disposition of cases. The Sandiganbayan denied his motion and subsequent motion for reconsideration.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion in refusing to quash the Informations despite the alleged inordinate delay in the preliminary investigation proceedings, which violated petitioner’s constitutional right to speedy disposition of cases.

RULING

Yes. The Supreme Court granted the Petition for Certiorari, reversed and set aside the Sandiganbayan Resolutions, and ordered the dismissal of the charges against petitioner. The Court found that the preliminary investigation conducted by the Office of the Ombudsman was attended by inordinate delay, violating petitioner’s right to speedy disposition of cases. The period from the filing of the complaint on June 29, 2011, to the filing of the Informations on September 29, 2017, spanned six years, three months, and one day. Applying the balancing test from Cagang v. Sandiganbayan, the Court found the delay was presumptively prejudicial. The government failed to justify the delay, as the complexity of the case and the conduct of petitioner did not cause it. The Court held that the right to speedy disposition of cases is violated when the proceeding is attended by vexatious, capricious, and oppressive delays. Consequently, the charges against petitioner were dismissed and he was acquitted.