G.R. No. 239878, February 28, 2022 | People vs Sandiganbayan, Casurra et al.
This is a petition for certiorari in a criminal case for the violation of Section 3(e) of Republic Act No. 3019 or the Anti-Graft and Corrupt Practices Act against local government officials in Surigao City. The respondents, who are government officials, allegedly entered into a contract with a private individual without public bidding, resulting in an overpricing of fertilizers.
After several years of investigation, the Ombudsman found probable cause to file an information before the Sandiganbayan. However, the respondents filed a motion to quash information/dismiss the case, and a motion to quash/hold in abeyance the release of the warrant of arrest, among others, on the ground of inordinate delay on the part of the Ombudsman in filing the case.
The Sandiganbayan granted the motion, resulting in the dismissal of the case against them.
The prosecution filed a petition for certiorari, arguing that the Sandiganbayan committed grave abuse of discretion in dismissing the cases.
RESOLUTION: The Supreme Court emphasized that the dismissal of the criminal case against the respondents constitutes acquittal, which can only be challenged through a petition for certiorari. To succeed in such a petition, the petitioner must show that the court or tribunal acted in a capricious, whimsical, arbitrary, or despotic manner.
The right to speedy disposition of cases is guaranteed by the Constitution, and the Supreme Court laid down guidelines in the case of Cagang v. Sandiganbayan to determine if there is a violation of this right. The right to speedy disposition of cases is different from the right to speedy trial and may be invoked before any tribunal, whether judicial or quasi-judicial.
The Supreme Court also emphasized that the burden of proof shifts depending on the circumstances. If the right to speedy disposition of cases is invoked within the given time periods, the defense has the burden of proving that the right was justifiably invoked. If the delay occurs beyond the given time period and the right is invoked, the prosecution has the burden of justifying the delay.
In this case, the Supreme Court found that there was a violation of the respondents' right to speedy disposition of cases. The Supreme Court also emphasized that the causes of the delays must be properly laid out and discussed by the relevant court in all cases of dismissals due to inordinate delay. It further noted that the right to speedy disposition of cases must be timely raised, and failure to do so may be deemed as a waiver of such right.
Overall, the Supreme Court found that the petition had no merit, and the Sandiganbayan did not commit grave abuse of discretion in dismissing the criminal cases. The Supreme Court's decision also highlights the need for courts to properly assess and consider delays in criminal proceedings.
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