G.R. No. 238877 - People vs. Sandiganbayan

Procedural Background
The People of the Philippines filed a Petition for Certiorari under Rule 65 of the Rules of Court.
The petition sought to annul and set aside three resolutions (dated 26 January 2018, 01 March 2018, and 05 April 2018) issued by the Sandiganbayan, Fourth Division.
The petition alleged that these resolutions were issued with grave abuse of discretion, amounting to lack or excess of jurisdiction, and that the right to speedy disposition of cases was violated.

Case Initiation and Investigative History
On 14 October 2008, Francisco H. Puey sent an e-mail complaint to the Ombudsman Regional Office VI against respondent Goldwyn V. Nifras, Chairman of the Bids and Awards Committee (BAC) of the City Government of Bacolod.
The complaint pertained to the alleged irregular award of a furniture contract for the Bacolod City New Government Center, valued at ₱50,000,000.00, to Comfac Corporation.
The matter was docketed under CPL-V-08-0801 and underwent a series of investigative reports and referrals, including a Final Evaluation Report recommending closure initially, and later an order for a preliminary investigation triggered by an anonymous tip on 24 May 2011.

Ombudsman's Role and Further Investigation
The case saw a consolidation of complaints when on 06 December 2012, the Ombudsman approved an Evaluation Report, consolidating CPL-V-11-0557 (from the anonymous complaint) with CPL-V-08-0801.
The Ombudsman approved a Review Final Evaluation Report (dated 16 October 2012) recommending both criminal charges for violation of Section 3(e) of RA 3019 (the Anti-Graft and Corrupt Practices Act) and administrative cases for Grave Misconduct and/or Gross Neglect of Duty against several respondents.
A Complaint Affidavit for preliminary investigation was filed on 01 March 2013, after which various respondents filed counter-affidavits and motions for extensions to file their responses.

Rulings by the Ombudsman and Subsequent Motions
On 13 December 2016, the Ombudsman approved a Joint Resolution finding respondents guilty of Grave Misconduct and Gross Neglect of Duty and recommending the filing of information against them.
Motions for reconsideration were filed by several respondents, including separate and joint motions, primarily arguing that the Ombudsman committed inordinate delay violating their right to speedy disposition of cases.
On 16 May 2017 and later on 14 September 2017, the Ombudsman denied the various motions for reconsideration filed by respondents.

Proceedings at the Sandiganbayan
The prosecution filed an Information before the Sandiganbayan on 24 November 2017, acting on the Ombudsman's findings.
Respondents, led by Evelio R. Leonardia and his co-accused, filed motions to dismiss the case based on:

Violation of their constitutional right to speedy disposition of cases by reason of the lengthy delay in proceedings, and
Lack of probable cause.

In the resolution dated 26 January 2018, the Sandiganbayan granted these motions to dismiss, causing the case to be dismissed.
A subsequent resolution dated 05 April 2018 dismissed the case against respondent Anabelle C. Badajos for lack of jurisdiction due to her occupying a position with Salary Grade “26,” though this dismissal was rendered without prejudice for re-filing with the proper court.

Abuse of Discretion and Jurisdiction
Whether the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction in dismissing the criminal case against the respondents.
Whether the dismissal of the case based on the violation of the right to speedy disposition of cases is proper.

Justification of Delay
Whether the prosecution adequately demonstrated that the Ombudsman's prolonged preliminary investigation (which lasted over three years) was justified by complex issues or voluminous evidence.
Whether the delay caused any substantial prejudice to the respondents.

Timeliness of Asserting the Right to a Speedy Disposition
Whether the respondents timely invoked their constitutional right to speedy disposition of cases during the preliminary investigation and before the Sandiganbayan.
The implications of respondent Badajos’s failure to timely assert her right on an equal protection basis.

Availability and Appropriateness of the Remedy of Certiorari
Whether certiorari is the proper remedy to contest the Sandiganbayan’s rulings, particularly when issues pertain to errors of jurisdiction versus errors of judgment.
Whether there exists a plain, speedy, and adequate remedy in the ordinary course of law against the resolutions being assailed.