Case Digest (G.R. No. 235965-66) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In RENE C. FIGUEROA v. SANDIGANBAYAN, G.R. Nos. 235965-66 (Feb. 15, 2022), petitioner Rene C. Figueroa, Executive Vice-President and Head of the Research and Development Department of the Philippine Amusement and Gaming Corporation (PAGCOR), challenged before the Supreme Court a Sandiganbayan Special Third Division resolution of October 11, 2017 in criminal cases SB16-CRM-0326 and SB16-CRM-0327. On June 21, 2011, PAGCOR filed with the Office of the Ombudsman a complaint for corruption against Figueroa and other officers, which was endorsed for preliminary investigation on July 19, 2011. The Ombudsman directed Figueroa to file a counter-affidavit on July 29; he received the order on August 16, sought and obtained a ten-day extension, and submitted his counter-affidavit on September 5, 2011. After more than three years, the Ombudsman issued a joint resolution finding probable cause on September 22, 2014, which was affirmed on reconsideration. Informations were filed on June 3, 201 Case Digest (G.R. No. 235965-66) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents
- On June 21, 2011, PAGCOR filed a corruption complaint against petitioner Rene C. Figueroa and other officers before the Office of the Ombudsman.
- July 19, 2011: Complaint endorsed for preliminary investigation.
- July 29, 2011: Ombudsman ordered respondents to file counter-affidavits within ten days; Figueroa received notice on August 16, 2011, and requested an additional ten days.
- September 5, 2011: Figueroa filed his counter-affidavit.
- September 22, 2014: Ombudsman issued joint resolution finding probable cause for two counts of RA 3019, Section 3(e).
- Motions for reconsideration by Figueroa were denied on January 28, 2015.
- Proceedings before the Sandiganbayan and Petition for Certiorari
- June 3, 2016: Informations filed in Sandiganbayan (SB16-CRM-0326, SB16-CRM-0327).
- March 6, 2017: Ombudsman moved to amend informations to correct names and designation; amendments approved and filed same day.
- July 4, 2017: Sandiganbayan admitted amended informations as formal and not altering the offense or defenses.
- July 20, 2017: Figueroa moved to quash the informations, alleging inordinate delay violating his right to speedy disposition of cases.
- October 11, 2017: Sandiganbayan denied the motion to quash, finding the delay reasonable and noting Figueroa’s failure to raise the issue before the Ombudsman.
- Figueroa’s motion for reconsideration was denied, prompting his Petition for Certiorari and Prohibition under Rule 65.
Issues:
- Whether the delay in the conduct of the preliminary investigation by the Ombudsman amounted to an unreasonable or oppressive delay violating Figueroa’s constitutional right to speedy disposition of cases.
- Whether Figueroa waived his right to speedy disposition of cases by failing to assert it before the Ombudsman.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)