Case Digest (G.R. No. 231144)
Facts:
In Republic of the Philippines v. Sandiganbayan and Leonardo B. Roman, petition G.R. No. 231144, decided October 18, 2021, the State assailed Sandiganbayan resolutions granting former Bataan Governor Leonardo B. Roman’s motion to quash for alleged violation of his constitutional right to speedy disposition of cases. In November 2003, Roman awarded a ₱3,660,000 contract to V.F. Construction for a mini‐theater at Bataan State College, certified its completion on February 23, 2004, and caused disbursement of ₱3,310,636.36 by Land Bank checks. A successor governor’s August 2004 inspection revealed the project unfinished. On September 1, 2004, Enrique T. Garcia, Jr. filed a complaint before the Office of the Ombudsman imputed with malversation through falsification and graft under R.A. 3019, which on May 30, 2006 was dismissed for lack of probable cause; the dismissal was affirmed on October 9, 2009. Garcia procured certiorari relief from the Supreme Court, which in November 2014 ordCase Digest (G.R. No. 231144)
Facts:
- Background of the Project and Contract
- Leonardo B. Roman, then-Governor of Bataan, entered into a contract in November 2003 with V.F. Construction to build a mini-theater at Bataan State College, Abucay Campus, for ₱3,660,000.00.
- On February 23, 2004, Roman issued a Certificate of Acceptance and an Affidavit attesting to the project’s full completion. Two Land Bank checks totaling ₱3,310,636.36 were later released to V.F. Construction, which issued corresponding receipts.
- Discovery of Alleged Deficiencies and Initial Complaint
- In August 2004, Roman’s successor, Enrique T. Garcia, Jr., found the theater incomplete and filed a complaint on September 1, 2004, for malversation through falsification (RPC Arts. 217 and 171) and graft (RA 3019 § 3[a] & [e]) against Roman, various provincial officials, and the contractor.
- The Office of the Ombudsman, on May 30, 2006 (approved June 23, 2008), dismissed charges against Roman for lack of probable cause but proceeded with falsification charges against other officials. A motion for reconsideration by Garcia was denied on October 9, 2009.
- Supreme Court Certiorari and Information Filing
- Garcia filed a certiorari petition on July 22, 2011, arguing grave abuse in dismissing graft charges against Roman; on November 19, 2014, the Supreme Court partially granted relief and ordered the Ombudsman to file an information under RA 3019 § 3(e) against Roman.
- On February 13, 2015, the Ombudsman filed the Information before the Sandiganbayan charging Roman and co-accused with conspiring to cause undue injury and unwarranted benefit amounting to ₱3,660,000.00.
- Motions and Sandiganbayan Resolutions
- Roman filed motions to suspend Sandiganbayan proceedings pending his SC motion for reconsideration; SB initially denied (Sept. 16, 2015), then granted (Feb. 15, 2016). The SC ultimately denied Roman’s reconsideration (Aug. 3, 2016).
- On October 14, 2016, Roman filed an Urgent Motion to Quash the Information, asserting violation of his constitutional right to a speedy disposition of cases due to an 11-year lapse from the complaint’s filing to the Information.
- The Sandiganbayan granted the motion (Dec. 14, 2016) and denied the prosecution’s reconsideration (Mar. 2, 2017), dismissing the case for inordinate delay in the preliminary investigation and finding prejudice to Roman.
- Petition for Certiorari to the Supreme Court
- The People of the Philippines questioned SB’s ruling, contending no vexatious or oppressive delay, that Roman waived his right by inaction, and that SB miscomputed the delay period and misappreciated prejudice.
- Roman maintained he timely asserted his right upon SC’s directive, did not waive it, and suffered genuine prejudice from protracted proceedings.
Issues:
- Whether private respondent Roman’s constitutional right to a speedy disposition of cases was violated by inordinate delay.
- Whether the Sandiganbayan erred in granting Roman’s Urgent Motion to Quash the Information on the ground of such violation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)