G.R. No. 191411 - Coscolluela vs. Sandiganbayan

Rafael L. Coscolluela served as Governor of Negros Occidental for three terms until June 30, 2001. Edwin N. Nacionales was his Special Projects Division Head, Jose Ma. G. Amugod was Nacionales’s subordinate, and Ernesto P. Malvas was Provincial Health Officer.
On November 7, 2001, People’s Graftwatch wrote to the Office of the Ombudsman—Visayas requesting investigation into an alleged anomalous ₱20,000,000 purchase of medical and agricultural equipment a month before Coscolluela left office.

The Ombudsman’s Case Building Team issued a Final Evaluation Report on April 16, 2002 upgrading the complaint into a criminal case. Investigating Officer Butch E. CaAares found probable cause on March 27, 2003 and prepared an Information the same date, but final approval by Acting Ombudsman Orlando C. Casimiro was only on May 21, 2009. The Information was filed with the Sandiganbayan on June 19, 2009.
Coscolluela filed a Motion to Quash on July 9, 2009, for violation of the right to speedy disposition; Nacionales, Malvas, and Amugod adopted it. The Sandiganbayan denied the motion on October 6, 2009 and denied motions for reconsideration on February 10, 2010.

Whether the Sandiganbayan gravely abused its discretion in ruling that petitioners’ right to a speedy disposition of cases was not violated.