G.R. No. 195668 - People vs. Inovero

Petitioner Rodolfo G. Valencia, former Governor of Oriental Mindoro, was charged before the Sandiganbayan with violation of Section 3(e) of Republic Act No. 3019 (Anti-graft and Corrupt Practices Act) on February 10, 1999.
The charge involved the alleged unlawful appointment of Cresente Umbao as Sangguniang Bayan member of Pola, Oriental Mindoro, within the prohibited one-year period after the 1992 elections, in violation of Sec. 6, Art IX B of the Constitution.
Accusations included manifest partiality, evident bad faith, or gross inexcusable negligence causing undue injury to the Province of Oriental Mindoro.

Rodolfo G. Valencia won the gubernatorial race in May 1992 local elections.
Cresente Umbao ran for councilor of the Municipality of Pola in the same election but lost.
A seat in the Sangguniang Bayan of Pola was vacated due to the death of Councilor Antonio Mercene, Jr., on October 17, 1992.
On December 1, 1992, Valencia appointed Umbao to the vacant councilor position.

Petitioner pled not guilty on arraignment on April 13, 1999.
On March 24, 2003, parties submitted a Joint Stipulation of Facts detailing the above facts for pre-trial purposes; however, petitioner never signed the document fully.
Prosecutor Danilo F. Salindong rested the prosecution's case on January 12, 2004, based solely on the Joint Stipulation of Facts, waiving testimonial evidence.
Petitioner filed a Motion for Leave to File Demurrer to Evidence on January 19, 2004, citing the absence of evidence substantiating the charge and challenging the admissibility of the unsigned Joint Stipulation.
The prosecution opposed the motion, alleging it was premature as the stipulation was yet to be formally offered.

The Sandiganbayan repeatedly ordered petitioner to sign the Joint Stipulation of Facts and the Pre-trial Order embodying it.
Petitioner refused, alleging lack of authorization of his previous counsel and delayed knowledge of the stipulation.
On June 14, 2004, the Sandiganbayan recalled the Pre-trial Order, denied the motion for leave to file demurrer to evidence, and set the case for presentation of prosecution evidence.
Petitioner’s motion for reconsideration was denied on July 28, 2004.
No temporary restraining order or preliminary injunction was issued; prosecution proceeded with evidence presentation.

Petitioner was suspended pendente lite by the Sandiganbayan in July 2005.
Petitioner had multiple granted travel requests abroad during trial.
There were significant delays and adjournments in trial schedules, partly due to retirements and unavailability of prosecution witnesses.
Petitioner did not invoke his right to a speedy trial throughout the proceedings until the motion for reconsideration.

Whether petitioner’s Motion for Leave to File Demurrer to Evidence was premature.
Whether the prosecution may present evidence after orally manifesting its intention to rest its case.
Whether petitioner was denied his constitutional right to a speedy trial.