Title
People vs. Sandiganbayan
Case
G.R. No. 239878
Decision Date
Feb 28, 2022
Local officials accused of graft in a P5M fertilizer procurement without bidding; case dismissed due to inordinate delay violating their right to speedy disposition.

Case Summary (G.R. No. 239878)

Petitioner

People of the Philippines, represented by the Office of the Special Prosecutor

Respondents

Casurra, Edera, Monteros, Geotina, Elumba, Lozada, and Palacio

Key Dates

– June 14, 2006; March 19, 2007 – COA issues and amends Notice of Disallowance
– July 4, 2011 – Task Force Abono files complaint with Ombudsman
– October 5, 2016 – Ombudsman finds probable cause for RA 3019 violation
– March 22, 2017 – Ombudsman approves resolution
– May 2, 2017 – Information filed before Sandiganbayan
– November 27, 2017 and April 18, 2018 – Sandiganbayan grants motions to quash and dismisses case
– February 28, 2022 – Supreme Court decision

Applicable Law

– 1987 Philippine Constitution, Article III, Section 16 (right to speedy disposition of cases)
– Republic Act No. 3019, Section 3(e) (“Anti-Graft and Corrupt Practices Act”)
– Republic Act No. 9184 (“Government Procurement Reform Act”) and its IRR

Factual Background

Surigao City received ₱5 million under the Farm Inputs and Farm Implements Program. City officials entered into a direct contrato with Rosa “Mia” Trading for 3,332 kg of fertilizers at ₱1,500/kg (total ₱4,998,000) without public bidding. COA post-audit revealed overpricing of approximately ₱4,495,500 and issued a Notice of Disallowance.

Proceedings Before the Sandiganbayan

An Information for violation of RA 3019 § 3(e) was filed on May 2, 2017. Monteros, later joined by Casurra, Edera, Geotina, Elumba, and Lozada, moved to quash the Information for inordinate delay in preliminary investigation (11 years 3 months from COA NOD to filing). They also sought to hold in abeyance the warrant, and to defer arraignment. The Office of the Special Prosecutor opposed.

Grounds for Quash Motions

Respondents asserted that:

  1. Their right to speedy disposition was violated by the Ombudsman’s delay from 2006 (COA NOD) to 2017 (Information).
  2. This inordinate lapse divested the Ombudsman of jurisdiction and rendered the Information void.

Sandiganbayan’s Dismissal

By Resolution dated November 27, 2017, and reaffirmed on April 18, 2018, the court:
– Calculated over 11 years delay from COA audit to Information filing
– Rejected prosecution’s complexity excuse
– Found no attributable delay to respondents
– Concluded prejudice, anxiety, and embarrassment suffered by respondents
– Quashed the Information and dismissed the case

Prosecution’s Certiorari Petition

The People challenged the Sandiganbayan resolutions for grave abuse of discretion, arguing that:
– The Balancing Test under the right to speedy disposition was ignored
– Fact-finding period should not be counted in computing delay
– Delay was reasonable given Ombudsman’s caseload and case complexity
– Respondents failed to timely invoke the right and did not prove actual prejudice

Constitutional Right to Speedy Disposition

Under the 1987 Constitution, Article III, Section 16 guarantees a speedy disposition of cases before judicial or quasi-judicial bodies, including the Ombudsman and Sandiganbayan.

Cagang Guidelines on Delay

In Cagang v. Sandiganbayan, the Court held that:

  1. Only the period for preliminary investigation (from formal complaint to filing of Information) is counted, excluding fact-finding investigations.
  2. If right is invoked beyond prescribed timeframes, prosecution bears burden to justify delay:
    a. Adherence to procedural rules;
    b. Complexity and volume of evidence made delay inevitable;
    c. No prejudice to the accused.

Computation of Delay

– Preliminary investigation commenced July 4, 2011 (complaint filing)
– Information filed September 11, 2017
– Total lapse: 6 years, 2 months, 7 days

Burden of Proof

Respondents first invoked the right in their motion for reconsideration of the Ombudsman’s October 5, 2016 resolution. This invocation occurred after expiration of rule-based periods (Rule 112, Rules of Court, by suppletory application), shifting burden to the prosecution to justify the 6-year delay.

Assessment of Justification for Delay

The prosecution failed to prove that:
– Procedural periods for preliminary investigation were observed (10 + 5 + 1

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