G.R. Nos. L-72335-39 March 21, 1988
FRANCISCO S. TATAD, petitioner, vs. THE SANDIGANBAYAN, and THE TANODBAYAN, respondents.

FACTS

The petitioner, Francisco S. Tatad, former Minister of Public Information, sought to annul the resolutions of the Tanodbayan and Sandiganbayan and to enjoin the proceedings in five criminal cases filed against him for alleged violations of the Anti-Graft and Corrupt Practices Act (R.A. No. 3019). The charges originated from a 1974 report filed with the Presidential Security Command, which was later formally lodged as a complaint with the Tanodbayan in December 1979. The Tanodbayan referred the matter for a fact-finding investigation in April 1980, which concluded in June 1980 with a recommendation for legal action. Despite the completion of affidavits and counter-affidavits by October 1982, the Tanodbayan only approved a resolution recommending the filing of informations in April 1985, and the cases were finally filed with the Sandiganbayan in June 1985.
The informations accused Tatad of bribery, giving unwarranted benefits to a corporation controlled by a relative, and failure to file his Statement of Assets and Liabilities for three calendar years. Tatad moved to quash the informations, arguing that the inordinate delay of nearly three years from the completion of the preliminary investigation to the filing of the cases violated his constitutional right to a speedy disposition. The Sandiganbayan denied his motion, prompting this petition.

ISSUE

Whether the inordinate delay in terminating the preliminary investigation and filing the informations violated petitioner’s constitutional right to due process and to a speedy disposition of the cases against him.

RULING

Yes. The Supreme Court granted the petition and ordered the dismissal of the criminal cases. The Court emphasized that the constitutional right to a speedy disposition of cases is not limited to the period after a formal complaint or information is filed but extends to all stages of a governmental investigation, including preliminary investigations conducted by the Tanodbayan. The Court found the delay of almost three years from the submission of the last affidavits in October 1982 to the filing of the informations in June 1985 to be vexatious, capricious, and oppressive.
The legal logic is grounded in the essence of the right to a speedy disposition, which is to prevent the oppressive use of prolonged legal processes. The Court rejected the Sandiganbayan’s speculative justification that the delay was due to a “painstaking and gruelling scrutiny” of the evidence against a former high-ranking official, noting this suggested an unacceptable double standard. It further reasoned that three of the five charges were for simple, non-complex failures to file asset statements, which did not warrant such protracted review. While the absence of a preliminary investigation can be remedied, an undue delay in its conduct cannot be corrected, as time lost is irretrievable. This violation of a fundamental right rendered the subsequent proceedings void. Consequently, the informations were dismissed for infringing upon the petitioner’s constitutional guarantees.