G.R. Nos. 247414-18. July 06, 2022
ROLANDO MAGAÑA PACURIBOT, PETITIONER, VS. HONORABLE SANDIGANBAYAN (SECOND DIVISION) AND PEOPLE OF THE PHILIPPINES, RESPONDENTS.

FACTS

Petitioner Rolando Magaña Pacuribot, the City Engineer of Cagayan de Oro City, was charged with multiple counts of violating Section 3(e) of R.A. 3019 before the Sandiganbayan. The charges stemmed from complaints filed in February 2015 alleging the illegal award of lease contracts for heavy equipment to two corporations without public bidding. The Office of the Ombudsman-Mindanao conducted a fact-finding investigation, concluding on October 30, 2015, and subsequently filed complaints. After preliminary investigation, several Resolutions finding probable cause were approved by then Ombudsman Conchita Carpio Morales between June 2016 and June 2017. Corresponding Informations were filed with the Sandiganbayan from June 2017 to May 2018.
Pacuribot filed Omnibus Motions to quash the Informations, arguing inordinate delay in the preliminary investigation, which spanned approximately three years from the filing of the complaint to the filing of the Informations, thereby violating his constitutional right to speedy disposition of cases. The Sandiganbayan denied all motions and subsequent motions for reconsideration, applying a balancing test and finding no violation, prompting Pacuribot to file this Petition for Certiorari.

ISSUE

Whether the Sandiganbayan acted with grave abuse of discretion in finding that Pacuribot’s right to speedy disposition of cases was not violated.

RULING

The Petition is granted. The Supreme Court found that the Sandiganbayan committed grave abuse of discretion in ruling that no inordinate delay occurred. Applying the comprehensive guidelines set forth in Cagang v. Sandiganbayan, the Court emphasized that the right to speedy disposition of cases attaches from the start of a fact-finding investigation if it is conducted by the same agency that conducts the preliminary investigation. Here, the period for delay analysis commenced on February 3, 2015, when the complaint was filed, and ended when the Informations were filed in court, resulting in delays ranging from two years and four months to over three years. The Court rejected the Ombudsman’s justification of case complexity and heavy workload as insufficient to excuse the protracted delay, noting the absence of any compelling reason offered for the lengthy intervals, particularly the significant gap between the fact-finding conclusion in October 2015 and the Ombudsman’s approval of resolutions much later. The delay was deemed presumptively prejudicial, and the government failed to rebut this presumption. Consequently, the criminal cases against Pacuribot were dismissed for violation of his right to speedy disposition of cases.