G.R. No. 249243 - Palacpac vs. Sandiganbayan, 5th Division

The case involves petitioner Merle Bautista Palacpac, former Chief of the National Plant Quarantine Services Division of the Bureau of Plant and Industry, challenging the decisions of the Sandiganbayan (Fifth Division) and the Office of the Special Prosecutor (Ombudsman's office).
The proceedings arose from criminal charges related to violations of the Anti-Graft and Corrupt Practices Act (Republic Act No. 3019) and alleged grave misconduct under Civil Service rules.

A Complaint was filed on May 30, 2016 by the Field Investigation Office (FIO) II of the Ombudsman's office against several accused, including petitioner, for:

Violations of Section 3(e) and (j) of RA 3019.
Grave misconduct and conduct prejudicial to the best interest of the service under Section 46(A)(3) and (B)(8) of Civil Service Resolution No. 1101502.

Petitioner, a key government official, was implicated among other public officers and private individuals.

On January 29, 2018, Graft Investigation and Prosecution Officer III (GIPO III) Bonifacio G. Mandrilla issued a Resolution finding probable cause against the accused, including petitioner, for violation of Section 3(e) of RA 3019.
Subsequently, petitioner filed a Motion for Reconsideration on May 9, 2018, which was denied on August 30, 2018 by the same investigating officer.

On March 15, 2019, GIPO III Mandrilla filed an Information before the Sandiganbayan.
The Information charged several public officers (including petitioner) and private individuals with conspiracy, abuse of authority, and other offenses related to the issuance of import permits for garlic.
The allegations detailed a scheme involving the formation of the National Garlic Action Team (NGAT) and improper issuance of import permits that led to price manipulation and undue benefits for private enterprises.

To quash the Information on the ground that it did not state the approximate dates of the commission of the offense, thus not conforming to legal requirements.
To assert that her right to a speedy disposition of the case was violated.

After the first Resolution dated July 24, 2019 denied her motion, petitioner filed a Motion for Reconsideration.
The Sandiganbayan subsequently issued a second Resolution on September 4, 2019, again denying petitioner's motion.

Petitioner contended that the Sandiganbayan committed grave abuse of discretion amounting to lack of jurisdiction by:

Denying her Omnibus Motion on technical grounds.
Excluding Section 3(e) of Rule 117 as a plausible ground for quashing the Information.
Ruling that the Information is valid despite its alleged failure to state the approximate dates of the offense.
Holding that the Ombudsman retained authority to file the Information, notwithstanding alleged violations of her right to speedy disposition.
Finding erroneously that the Information was not duplicitous in nature.

Additionally, petitioner argued that the delay in the resolution of the case—from the filing of the Complaint in 2016 until the filing of the Information in 2019—amounted to a violation of her constitutional right to speedy trial and due process.

Whether the Sandiganbayan acted with grave abuse of discretion amounting to lack of jurisdiction by denying petitioner’s:

The failure of the Information to state the approximate dates of the alleged commission of the offense.
The alleged deprivation of petitioner’s right to the speedy disposition of her case.
The contention that there exists an inherent conflict between Section 2(c) of the Revised Guidelines for Continuous Trial and Section 1, Rule X of the 2018 Revised Internal Rules of the Sandiganbayan.
The argument that the Information is defective for allegedly charging more than one offense (i.e., being duplicitous).