GR L 25769; (December, 1974) (Digest)
G.R. No. L-25769 December 10, 1974
FRANCISCO FLORES and FRANCISCO ANGEL, petitioners, vs. PEOPLE OF THE PHILIPPINES, respondent.
FACTS
Petitioners Francisco Flores and Francisco Angel were convicted of robbery by the trial court on November 29, 1955, following an information filed in 1951. They filed a notice of appeal on December 8, 1955. The Court of Appeals took no action for three years until February 10, 1958, when it remanded the case for a rehearing of a material witness. This resolution was amended on August 5, 1959, setting aside the conviction and ordering a new trial to receive new evidence for the defense. The case was returned to the lower court.
The rehearing encountered significant delays. For about a year, the offended party failed to appear despite multiple settings. When he finally testified, his recollection was poor, and he failed to identify the accused. Instead of rendering a new decision, the lower court returned the records to the Court of Appeals. From that point, five more years passed without action. By May 10, 1965, nearly a decade had elapsed since the appeal was filed. Petitioners moved to dismiss the case, invoking their constitutional right to a speedy trial. The Court of Appeals denied their motions.
ISSUE
Whether the prolonged delay in the disposition of the criminal case violated the petitioners’ constitutional right to a speedy trial, warranting the dismissal of the case.
RULING
Yes. The Supreme Court granted the petition and ordered the dismissal of the criminal case. The constitutional right to a speedy trial, protected under both the 1935 and 1973 Constitutions, is designed to protect the accused from vexatious, capricious, and oppressive delays. Its purpose is to spare an innocent person from prolonged anxiety and to ensure a guilty person is not kept long in suspense, within a period compatible with presenting a defense.
The Court found the delay in this case—spanning from December 8, 1955, to May 10, 1965—to be inordinate and unjustified. The period of inactivity, including the three-year initial lapse by the Court of Appeals and the subsequent five-year delay after the remand, constituted a clear violation. Jurisprudence establishes that such a violation entitles the accused to relief through certiorari for the dismissal of the case. The Court rejected the procedural objection that the People of the Philippines was an improper party, holding that technicalities must yield to the substantive right at stake. The petition was effectively directed against the Court of Appeals’ inaction, and the defenses raised by the State were insufficient to justify the delay. Consequently, the orders of the Court of Appeals were set aside and the criminal case was dismissed.