Case Digest (G.R. No. 72335-39) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Francisco S. Tatad v. The Sandiganbayan and The Tanodbayan, petitioner Francisco S. Tatad, then Minister of Public Information, was accused under Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act) in five separate informations (Criminal Cases Nos. 10499–10503) filed before the Sandiganbayan. The original allegations arose from a “report” by Antonio de los Reyes to the Presidential Security Command’s Legal Panel in October 1974, but no action was taken until December 12, 1979—shortly after Tatad’s resignation was accepted on January 26, 1980—when de los Reyes filed a formal complaint with the Tanodbayan. The Tanodbayan referred the matter on April 1, 1980 to the Criminal Investigation Service (CIS), whose June 16, 1980 report recommended charges for violations of Sections 3(b), 3(e), and 7 of RA 3019. After affidavits and counter-affidavits were completed by October 25, 1982, the Tanodbayan inexplicably delayed issuing its resolution until April 1, 1985 (approved ... Case Digest (G.R. No. 72335-39) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Origin of the complaint
- October 1974 – Antonio de los Reyes, former Executive Assistant of DPI, filed a report with the PSC Legal Panel accusing Francisco Tatad, then DPI Secretary, of graft under R.A. 3019; no immediate action was taken.
- December 12, 1979 – De los Reyes filed a formal complaint (TBP Case No. 8005-16-07) with the Tanodbayan, repeating the 1974 charges shortly after Tatad’s resignation as Minister of Public Information.
- Preliminary investigation
- April 1, 1980 – Tanodbayan referred the complaint to CIS, PSC, for fact-finding; June 16, 1980 – CIS recommended graft charges against Tatad.
- October 25, 1982 – All affidavits and counter-affidavits were on record; preliminary investigation remained unresolved for nearly three years.
- Filing of informations and motions to quash
- June 12, 1985 – Tanodbayan filed five informations against Tatad for violations of Sections 3(b), 3(e) and 7 of R.A. 3019 (Crim. Cases Nos. 10499–10503) with the Sandiganbayan.
- July 22, 1985 – Tatad filed a consolidated motion to quash based on due-process violation, speedy-trial rights, prescription, lack of prima facie case, and non-offense in one information; denied by Tanodbayan and Sandiganbayan (resolutions of August 9, August 12, and September 17, 1985).
- Petition for certiorari and injunction
- October 16, 1985 – Tatad petitioned the Supreme Court for certiorari, prohibition and preliminary injunction to annul the resolutions and enjoin further proceedings.
- October 22, 1985 – SC issued a temporary restraining order stopping the trials; respondents filed comments (Jan. 6, 1986) and new officials manifested intentions to pursue the case; Tatad filed a motion for re-evaluation with Tanodbayan (July 21, 1986).
Issues:
- Whether the prolonged preliminary investigation and delayed filing of informations deprived Tatad of due process and his right to a speedy disposition of cases.
- Whether the crimes charged have prescribed.
- Whether the prosecution was discriminatory or politically motivated.
- Whether the Sandiganbayan should enforce the ten-day period for resolution of preliminary investigations under P.D. 911 as mandatory.
- Whether the informations lack a prima facie case.
- Whether the Sandiganbayan erred in not ruling on Amnesty issues raised by Tatad.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)