Facts:
Jaime T. Bernat, along with several co-accused, was charged before the Sandiganbayan with a violation of Section 3(e) of Republic Act No. 3019, known as the Anti-Graft and Corrupt Practices Act, on August 14, 1991. After arraignment and the presentation of evidence, the case was submitted for decision on August 23, 1994, before the Sandiganbayan’s Second Division. Due to a reorganization of the Sandiganbayan under Administrative Order 266-97, the case was transferred to the Fifth Division.
Initially assigned to Justice Godofredo Legaspi, the case was later reassigned to Justice Ma. Cristina G. Cortez-Estrada in November 1998. In early 2002, Justice Cortez-Estrada, while preparing the decision, discovered that the transcript of stenographic notes for November 26, 1993, was missing. The Clerk of Court notified the parties and scheduled a conference on April 19, 2002. Bernat, however, expressed strong aversion to further proceedings due to the missing transcript and subsequently filed a Motion to Dismiss on September 4, 2002, citing an 8-year delay in decision-making, which he believed violated his constitutional right to a speedy disposition.
Issues:
The legal issue raised is whether the constitutional right to a speedy disposition of a case was violated by the Sandiganbayan’s delay in deciding the case which remained unresolved over 8 years after being submitted for decision.
Court’s Decision:
The Supreme Court dismissed the petition for certiorari, holding that there was no violation of the constitutional right to a speedy disposition of the case. The Court reasoned that the determination of unreasonable delay is relative and must account for the specific circumstances of each case. Considering factors such as the length of the delay, reasons for the delay, the accused’s assertion or failure to assert their rights, and the prejudice caused by the delay, the Court found that Bernat did not assert his right during the 8-year delay until after the missing transcript was brought to his attention. The Court urged the Sandiganbayan to decide the case within six months from the pronouncement of this decision.
Doctrine:
The ruling reiterates the doctrine that the right to a speedy disposition of cases is relative and must be determined on a case-by-case basis, with the factors mentioned by the Court serving as guidelines for determining whether the delays were vexatious, capricious, and oppressive.
Historical Background:
This case emerged during a period where the Philippine judicial system was undergoing reorganization and experiencing systemic delays due to various factors, such as the loss of court records and procedural issues. The decision of the Supreme Court in this case upholds the principle that while the right to speedy disposition of cases is fundamental, it is not an absolute right and must be balanced against the circumstances of each case and the interests of justice. It also underscores the role of the accused in preserving and asserting such rights within a reasonable period.
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