**Facts:**
This case arose from the failure to remit contributions to the Government Service Insurance System (GSIS) by the Municipality of Lantawan, Basilan, with arrearages dating back to 1997. When Tahira S. Ismael became Mayor and Aida U. Ajijon served as Municipal Treasurer, the overdue amounts increased due to penalties. Despite receiving collection letters from 1999 to 2003, the obligations remained unsettled, resulting in suspended loan privileges for GSIS members. A complaint for malversation of public funds led to their indictment for violation of Section 3(e) of RA No. 3019 and Sections 3.3.1 and 3.4 of the IRR of RA No. 8291.
The Sandiganbayan, in its Decision dated August 2, 2017, convicted both Ismael and Ajijon, sentencing them to imprisonment and perpetual disqualification from public office. Their subsequent Motion for Reconsideration was denied, prompting the filing of this appeal under Rule 45 of the Revised Rules of Court, challenging the validity of the Informations and alleging violations of their constitutional rights.
**Issues:**
1. Whether petitioners’ right to be informed of the nature and cause of the accusations against them was violated due to the non-inclusion of other alleged conspirators in the Informations.
2. Whether petitioners’ right to the speedy disposition of cases was violated considering the length of time from the filing of the Informations to the resolution of their case.
3. Whether the Sandiganbayan correctly convicted petitioners under RA No. 3019 and the IRR of RA No. 8291.
**Court’s Decision:**
1. On the first issue, the Court held that the non-inclusion of other conspirators does not, by itself, violate the right to be informed of the nature and cause of the accusation, provided that the Informations sufficiently state the acts constituting the offense.
2. Regarding the second issue, the Court ruled that mere delay in the proceedings is not tantamount to a violation of the right to speedy disposition of cases or speedy trial. The Court pointed out that petitioners contributed to the delay and did not demonstrate that the delay resulted in significant prejudice to their cause.
3. On the substantive matters, the Court found no basis to hold petitioners guilty under Section 3(e) of RA No. 3019 due to the lack of proof of evident bad faith or gross inexcusable negligence. However, they were held liable under RA No. 8291 for the failure to remit GSIS contributions since the offense therein is categorized as mala prohibita, requiring only the intent to perpetrate the act.
**Doctrine:**
While failure to discharge a statutory duty does not automatically entail bad faith or negligence, the imposition of liability requires a clear demonstration of such elements when charged under RA No. 3019. In contrast, offenses classified as mala prohibita, such as the non-remittance of GSIS contributions under RA No. 8291, establish liability through the mere act of violation, contingent on the proof of intent to commit the act.
**Class Notes:**
– In cases of mala prohibita, the prosecution needs to only prove the perpetration of the prohibited act, distinct from the necessity of evidencing malicious intent or negligence in crimes involving moral turpitude or violations requiring evident bad faith or gross negligence.
– The right to a speedy trial and the right to be informed of the nature and cause of the accusation are safeguarded by the Constitution. However, these rights may be deemed waived if the accused does not assert them timely or contributes to the delay in trial proceedings.
– Key legal provisions: Section 3(e) of RA No. 3019 and Sections 52(d) and (g) of RA No. 8291, along with pertinent sections of the IRR of RA No. 8291, are central to understanding the liabilities of public officers in the mismanagement of public funds or failure to remit statutory contributions.
**Historical Background:**
The case underscores the importance of statutory contributions like those to the GSIS and the legal repercussions for public officials who fail in their fiduciary duties to manage and remit such contributions timely. It reflects the judiciary’s role in holding public officials to account and ensuring that the rights of government employees and beneficiaries are protected. The decision also exemplifies the balance between procedural rights of the accused and the substantive need for accountability in public service.
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