Title
Malones y Malificio vs. Sandiganbayan, 3rd and 7th Divisions
Case
G.R. No. 226887-88
Decision Date
Jul 20, 2022
Municipal officials accused of graft over garbage truck purchase without bidding; charges dismissed due to Ombudsman's inordinate delay, violating right to speedy case disposition.

Case Digest (G.R. No. 226887-88)
Expanded Legal Reasoning Model

Facts:

  • Parties and Nature of the Case
    • Petitioners: Mariano Malones and Edna M. Madarico, former public officials of the Municipality of Maasin, Iloilo (Mayor and Treasurer, respectively).
    • Respondents: Sandiganbayan (Third and Seventh Divisions) and the People of the Philippines.
    • Nature of the Case: A Petition for Certiorari under Rule 65 alleging grave abuse of discretion amounting to lack or excess of jurisdiction in the resolutions issued by the Sandiganbayan.
  • Background and Allegations
    • Incident and Complaint
      • On May 31, 2002, Winefredo C. Maternal, a former Sangguniang Bayan member, filed a complaint-affidavit before the Office of the Ombudsman.
      • The complaint pertained to irregularities in the acquisition of a garbage compactor truck from Tomitzu Corporation without public bidding, resulting in a loss of public funds amounting to P380,000.00.
    • Referral and Investigative Process
      • On August 27, 2002, the Ombudsman referred the complaint to the Regional Office VI of the Commission on Audit (COA).
      • The COA submitted an Evaluation Report on March 25, 2004.
      • On September 28, 2011, the Public Assistance and Corruption Prevention Office (PACPO) of the Ombudsman issued a Final Evaluation Report recommending criminal charges against petitioners and a co-accused.
    • Subsequent Proceedings before the Ombudsman
      • On March 12, 2012, PACPO filed its formal complaint-affidavit against petitioners.
      • On April 13, 2012, the Ombudsman directed petitioners and the co-accused to file their counter-affidavits.
      • Counter-affidavits were filed by Malones on July 18, 2012 and by Madarico on August 9, 2012. The co-accused did not file a counter-affidavit.
      • Petitioners raised a claim that their constitutional right to a speedy disposition of cases was violated since it took nearly a decade for the Ombudsman to act.
    • Referral to the Sandiganbayan
      • On August 29, 2013, the Ombudsman rendered a resolution recommending the filing of Informations against petitioners and the co-accused.
      • Petitioners filed a Motion for Reconsideration before the Ombudsman, which was denied on November 3, 2014.
    • Criminal Cases and Court Proceedings
      • Two Informations were filed on August 27, 2014 before the Sandiganbayan in Criminal Case Nos. SB-15-CRM-0092 and SB-15-CRM-0093.
      • The charges involved violation of Section 3(e) of R.A. No. 3019 and falsification of public/official documents relating to the acquisition of the garbage compactor truck.
      • On January 20, 2016, the Office of the Special Prosecutor (OSP) filed a Motion for Suspension Pendente Lite against Malones.
      • On June 7, 2016, while the cases were pending, the Third Division of the Sandiganbayan issued a resolution denying petitioners’ motion to dismiss their cases invoking their right to speedy disposition while granting the motion to suspend Malones.
      • On September 6, 2016, the Sandiganbayan, Third Division denied petitioners’ motion for reconsideration, prompting the present petition for certiorari.
  • Petition and Grounds for Relief
    • Petitioners allege that the delays in both the Ombudsman’s preliminary investigation and the subsequent proceedings before the Sandiganbayan violated their constitutional right to a speedy disposition of cases.
    • They contend that the proceedings suffered from vexatious, capricious, and oppressive delays.
    • Additionally, they argue that the Third Division overstepped its jurisdiction by ruling on matters even after the case had been raffled to the Seventh Division.

Issues:

  • Jurisdiction and Timeliness
    • Whether the Third Division of the Sandiganbayan committed grave abuse of discretion in denying petitioners’ motion to dismiss the criminal complaints on the ground of violation of their constitutional right to a speedy disposition of cases.
    • Whether the Third Division acted improperly by issuing resolutions on matters concerning cases that had already been raffled to the Seventh Division.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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