G.R. No. 247982 , April 28, 2021
Eduardo M. Cojuangco, Jr., Petitioner, vs. Sandiganbayan and the Presidential Commission on Good Government (PCGG), Respondents.

FACTS

On July 31, 1987, the PCGG filed Civil Case No. 0033 before the Sandiganbayan against petitioner Eduardo M. Cojuangco, Jr., a close associate of former President Ferdinand Marcos, and others for recovery of ill-gotten wealth. The complaint was amended multiple times, with the latest on August 23, 1991. On March 24, 1999, the Sandiganbayan allowed the subdivision of the complaint into eight separate cases. Petitioner is involved in six of these subdivided cases: Civil Case Nos. 0033-B, 0033-C, 0033-D, 0033-E, 0033-G, and 0033-H (subject cases). The pre-trial stages for these cases were completed between 2000 and 2003. However, the PCGG filed motions for partial summary judgment and/or judgment on the pleadings in all subject cases except 0033-H, which halted the pre-trial proceedings. These motions were denied by the Sandiganbayan on various dates from 2006 to 2016. The PCGG filed motions for reconsideration, which were also denied from 2008 to 2017. Petitioner, as early as 2003, raised the issue of delay and his right to speedy disposition of cases, filing motions to dismiss on these grounds in all subject cases except 0033-G, which were denied by the Sandiganbayan from 2014 to 2017. Despite the denials of the interlocutory motions, trial proper never commenced. On February 2, 2018, petitioner filed a manifestation and motion to include the cases in the court calendar, which was not acted upon. Petitioner filed the instant Petition for Prohibition on July 18, 2019, seeking to enjoin the Sandiganbayan from further exercising jurisdiction and to order the dismissal of the cases for violation of his constitutional rights to due process and speedy disposition of cases, alleging over 32 years of delay without trial.

ISSUE

Whether the Sandiganbayan should be prohibited from further exercising jurisdiction over the subject cases and whether said cases should be dismissed due to violation of petitioner’s constitutional rights to due process and speedy disposition of cases.

RULING

The Supreme Court granted the petition. The Court found that petitioner’s right to speedy disposition of cases was violated. Applying the four-factor balancing test (length of delay, reason for the delay, assertion of the right, and prejudice to the accused), the Court held: (1) The length of delay of over 32 years from the filing of the original complaint, or over 24 years from the subdivision of the cases, is inordinate and presumptively prejudicial. (2) The primary reason for the delay was the PCGG’s filing of multiple interlocutory motions (for partial summary judgment/judgment on the pleadings and motions for reconsideration), which were largely unmeritorious and caused significant postponements. The Sandiganbayan also failed to exercise strict control over the proceedings and to ensure continuous trial as mandated by the rules. (3) Petitioner asserted his right to speedy disposition at the earliest opportunity in 2003, in his oppositions to the PCGG’s motions, and repeatedly thereafter. (4) The delay caused prejudice to petitioner, including the fading of memories and the unavailability of witnesses and handling lawyers, impairing his ability to present a defense. The financial burden from the sequestration of properties also constituted economic prejudice. The Court ruled that the Sandiganbayan acted with grave abuse of discretion in allowing the inordinate delay. Consequently, the Sandiganbayan was prohibited from further proceeding with Civil Case Nos. 0033-B, 0033-C, 0033-D, 0033-E, 0033-G, and 0033-H, and said cases were ordered dismissed.