G.R. No. L-6483 November 27, 1953
EFIFANIO MANABAT, petitioner, vs. THE PROVINCIAL WARDEN OF NUEVA ECIJA, respondent.

FACTS

Petitioner Efifanio Manabat has been imprisoned since November 14, 1945, charged with robbery in band and murder in Criminal Cases Nos. 173 and 188 of the Court of First Instance of Nueva Ecija. Joint trial commenced on February 18-19, 1946, with the prosecution presenting only one witness. On April 13, 1946, petitioner escaped from jail and remained at large until his recapture on October 7, 1949. After his return to custody, hearings were set and postponed multiple times throughout 1951, sometimes by agreement of the parties, at the request of the prosecution, or upon motion of the defense counsel. From early 1952 onward, the trial faced further delays due to the presiding judge’s transfer, the unavailability of prosecution witnesses who had moved residences, the transfer of the stenographer who took the untranscribed notes, and the subsequent judge’s designation to hold sessions in another province. Petitioner filed a motion for speedy trial on September 23, 1952, and a pre-trial was set for December 4, 1952, but the judge failed to appear. Petitioner filed this habeas corpus petition on February 6, 1953, alleging denial of his constitutional right to a speedy trial and seeking release and termination of the criminal cases against him.

ISSUE

Whether the petitioner’s constitutional right to a speedy trial has been violated, warranting his release and the dismissal of the criminal cases against him.

RULING

The petition is denied. The Supreme Court held that the circumstances of the case do not justify the application of the ruling in Conde vs. Rivera, which ordered release due to a violation of the right to speedy trial. The Court found that a significant portion of the delay was attributable to the petitioner himself, specifically his escape from jail and his being at large for about four years, as well as his own requests for postponements in 1951. While the Court acknowledged that delays from early 1952 onward were not wholly justified and emphasized the constitutional guarantee of a speedy trial for both the accused and the state, the overall delay was not sufficient to warrant the extreme remedy of release and dismissal. The Court denied the petition for release and termination of the cases but urged and enjoined the Court of First Instance of Nueva Ecija and the Provincial Fiscal to try and terminate the cases as early as possible. A copy of the decision was ordered furnished to the Secretary of Justice and the Solicitor General.