Title
Alarilla vs. Sandiganbayan, 4th Division
Case
G.R. No. 236177-210
Decision Date
Feb 3, 2021
A mayor accused of malversation and falsification successfully challenged a nine-year delay in her case, leading to dismissal due to violation of her constitutional right to speedy disposition.
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Case Digest (G.R. No. 236177-210)

Facts:

Background of the Case

  • Petitioner Joan V. Alarilla was elected city mayor of Meycauayan, Bulacan, in May 2007 and was re-elected in 2010 and 2013.
  • On 18 January 2008, Rolando L. Lorenzo filed a complaint against Alarilla and her deceased husband, Eduardo A. Alarilla, before the Office of the Ombudsman for malversation through falsification of public documents, grave misconduct, and dishonesty.
  • Lorenzo alleged that during July and August 2007, Alarilla and her husband misappropriated Php5,130,329.14 by issuing 43 checks from public funds, falsely representing them as payments for goods and services that were never delivered or rendered.

Preliminary Investigation

  • On 07 May 2008, the Ombudsman directed Alarilla and her husband to file their counter-affidavits, which they submitted on 09 July 2008.
  • Alarilla's husband passed away on 04 March 2009, while the case was still pending.
  • Eight years later, on 07 March 2017, Alarilla received a Resolution dated 03 November 2016, finding probable cause to indict her for 33 counts of malversation through falsification and violation of Section 3(e) of Republic Act No. 3019.

Proceedings Before the Sandiganbayan

  • Alarilla filed a motion for reconsideration on 13 March 2017, arguing that her right to speedy disposition of cases was violated due to the nine-year delay in resolving the case.
  • The Ombudsman denied her motion on 24 March 2017.
  • On 11 September 2017, the Ombudsman filed one Information for violation of Section 3(e) of RA 3019 and 33 Informations for malversation through falsification before the Sandiganbayan.
  • Alarilla filed an Omnibus Motion on 15 September 2017, asserting inordinate delay and violation of her constitutional right to speedy disposition of cases.
  • The Sandiganbayan denied her motion on 18 October 2017, ruling that there was no undue delay and that Alarilla failed to timely assert her right.

Issue:

  • Whether the Sandiganbayan committed grave abuse of discretion in ruling that Alarilla's right to speedy disposition of cases was not violated despite the nine-year delay in the preliminary investigation.

Ruling:

  • The Supreme Court granted the petition, ruling that the Sandiganbayan gravely abused its discretion in denying Alarilla's motions.
  • The Court found that the Ombudsman's delay of almost nine years in conducting the preliminary investigation was inordinate and unjustified, violating Alarilla's constitutional right to speedy disposition of cases.
  • The Court annulled and set aside the Sandiganbayan's Resolutions dated 18 October 2017 and 17 November 2017 and ordered the dismissal of the criminal cases against Alarilla.

Ratio:

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