Facts:
Petitioners
Carmencita C. Daep,
Ameife L. Lacbain,
Arnold B. Calcina, and
Ernesto M. Millena were charged before the
Sandiganbayan—Fourth Division with violation of
Section 3(e) of R.A. No. 3019, as amended, for acts committed, in the Information, from
March to April 2004 or sometime prior or subsequent thereto, in the Municipality of Manito, Province of Albay, within the Sandiganbayan’s jurisdiction. The Information alleged that, while acting in their official capacities and taking advantage of their positions, petitioners caused
undue injury to the government and gave
unwarranted benefits to
Hexaphil Agriventures, Inc., by awarding a contract through
direct contracting for the purchase of four thousand two hundred eighty-five bottles of Hexaplus liquid fertilizer at
P700.00 per bottle, and by causing the disbursement of public funds in the amount of
P2,999,500.00, notwithstanding alleged ineligibility and other procurement irregularities connected with the “Fertilizer Fund Scam” under the Department of Agriculture’s GMA Program. On
August 16, 2016, petitioners filed an Urgent Motion for Judicial Determination of Probable Cause, also invoking—among other arguments—that the complaint should be dismissed due to alleged delay and claiming that the complaint was filed on
May 16, 2011, counter-affidavits were filed on
September 12, 2011, but the Office of the Ombudsman issued its Resolution only on
October 22, 2014, which they alleged was an unreasonable delay violating their rights to due process and
speedy disposition of cases. The Sandiganbayan denied the Urgent Motion in a Resolution dated
February 1, 2017, finding probable cause and holding there was no
inordinate delay, explaining that although the Ombudsman took approximately
three (3) years to conduct the preliminary investigation, the prosecution justified it due to the
complex issues,
voluminous documents, and
various witnesses. Petitioners’ Motion for Reconsideration was denied on
April 6, 2018. On
June 14, 2018, petitioners filed a Motion to Dismiss anew on the same constitutional ground, asserting that because the facts arose in
2004 and the complaint and Information were filed only in
2011 and
2016 respectively, dismissal was warranted; the Sandiganbayan denied the motion on
October 16, 2018, noting it was the
third motion raising the same inordinate-delay arguments, and denied reconsideration on
November 27, 2018, prompting the People to file a
Rule 65 petition before the Supreme Court.
Issues:
Whether petitioners’ constitutional right to
speedy disposition of cases was violated such that the Sandiganbayan gravely abused its discretion in denying their Motion to Dismiss on the ground of
inordinate delay.
Ruling:
Ratio:
Doctrine: