G.R. No. 137355-58 - Caballero vs. Sandiganbayan

Alfredo R. Enriquez – Administrator, Land Registration Authority (LRA)
Gener C. Endona – LRA Legal Officer and member of the Pre-qualifications, Bids and Awards Committee
Rhandolfo B. Amansec – Chief, LRA Inspection and Investigation Division

OMB-ADM-0-00-0415 (alleged violation of Section 4(a) of Republic Act No. 6713 and certain provisions under the Omnibus Rules under Executive Order No. 292)
OMB-ADM-0-00-0416 (alleged dishonesty and grave misconduct)
OMB-ADM-0-00-0417 (alleged gross neglect of duty, inefficiency, and non-compliance with Republic Act No. 7718, as amended)

OMB-0-00-0873 (alleged violation of Section 3(b) and (c) of Republic Act No. 3019, as amended)
OMB-0-00-0874 (alleged violation of Section 3(e) of Republic Act No. 3019, as amended)

The Fact-Finding and Intelligence Bureau (FFIB) of the Office of the Ombudsman filed separate Complaints-Affidavits charging petitioners in connection with the bidding of the Land Titling Computerization Project.

Petitioners submitted a Joint Counter-Affidavit vehemently denying the allegations.

July 12, 2002: Petitioners filed a Motion to Set Date for the simultaneous filing of Memoranda, which the respondent did not act upon.
December 12, 2002: Edilberto R. Feliciano (one of those charged) filed a Motion for Early Resolution, expressing alarm over the respondent’s inaction.
March 24, 2006: Petitioners filed a Motion to Dismiss all cases, alleging that the inordinate delay (over six years from filing and four years after the formal offer of evidence) had violated their constitutional right to a speedy disposition, causing reputational damage, anxiety, and loss of opportunities.

October 20, 2006: Petitioners filed the present petition for mandamus, invoking their constitutional right to a speedy disposition of their cases, contending that the respondent’s prolonged inaction amounted to grave abuse of discretion and, thus, a violation of due process.

The Office of the Ombudsman failed to resolve the administrative and criminal cases against them despite formal offer of evidence and several motions.
The delay has not only injured their reputation but also resulted in severe anxiety and tangible losses such as denied employment opportunities and retirement benefits.

Argued that the delay was due to the careful evaluation and thorough review of the evidence by the prosecutors, asserting that dismissing the cases would interfere with its discretionary powers.
Contended that the remedy of mandamus was not applicable since the issues involved the exercise of discretion rather than a clear ministerial duty.

Whether the petition for the writ of mandamus is an appropriate remedy under the circumstances.
Whether the respondent (Office of the Ombudsman) violated petitioners’ constitutional right to a speedy disposition of their cases by the inordinate delay in the resolution of both the administrative and criminal complaints.