**Facts:**
1. **June 5, 1982:** The Legaspi City Branch of the Central Bank is robbed, losing P19,731,320.00.
2. **June 6, 1982:** Modesto Licaros and four companions deliver stolen money to Home Savings Bank in Intramuros, Manila, where petitioner Abelardo B. Licaros is Vice Chairman and Treasurer.
3. **June 8-9, 1982:** Petitioner unsuccessfully attempts to report the incident to Gen. Fabian Ver and successfully reports to Central Bank officials the next day, leading to the recovery of money and apprehension of principal accused.
4. **July 6, 1982:** Tanodbayan files Information against several individuals for robbery, including petitioner as an accessory.
5. **November 1982 – January 1983:** Amended Information is filed, arraignment occurs, and Motion for Discharge as state witness for petitioner is filed and granted but later annulled by the Supreme Court.
6. **July 23, 1984 – October 1, 1984:** Prosecution files second motion for discharge which was denied, and case is initially deemed submitted for decision.
7. **1985-1986:** Case is reopened to hear additional testimony irrelevant to petitioner, petitioner files for Separate Trial and presents his defense.
8. **August 8, 1986:** Petitioner submits Formal Offer of Exhibits and prays for acquittal.
9. **October 8, 1986:** Sandiganbayan defers decision on petitioner’s case until the conclusion of proceedings against other accused.
10. **1986 – 2000:** Multiple motions by petitioner for resolution are filed, including Omnibus Motion to Dismiss, all unresolved.
11. **August 15, 2000:** Petitioner files motion to resolve, followed by reiterative motion for early resolution.
12. **August 28, 2001:** Case is finally deemed submitted for resolution at Supreme Court.
**Issues:**
1. **Main Issue:** Did the Sandiganbayan’s delay in resolving the case violate the petitioner’s constitutional right to a speedy disposition of his case?
2. **Procedural Issue:** Is mandamus an appropriate remedy to compel the Sandiganbayan to dismiss the case?
**Court’s Decision:**
1. **Speedy Disposition of Case:** The Supreme Court found an unexplained delay of over ten years since the case was deemed submitted for decision. The delay, attributed to reorganization and oversight without petitioner’s fault, was deemed to violate petitioner’s constitutional right. Petitioner had proactively asserted his right, showing no laches or procedural delays on his part.
2. **Doctrine:** The Court reiterated that the right to a speedy disposition of a case extends through all judicial stages and is a broader protection than the right to a speedy trial. The Court identified the necessity of the right to a speedy disposition being preserved post-submission for decision within prescribed periods.
3. **Mandamus:** The Court held that mandamus was an appropriate remedy due to gross abuse of discretion by the Sandiganbayan in delaying the decision, further emphasizing exceptions allowing mandamus in cases of manifest injustice from delay.
**Doctrine:**
1. **Constitutional Protections:** The right to speedy disposition is crucial and encompasses periods before, during, and after trial stages in criminal cases.
2. **Timing:** Failure to decide within statutory (90 days under PD 1606) or constitutional (12 months under Art. III, Sec. 15) periods constitutes a violation of due process rights.
3. **Dismissing Cases:** Unreasonable delays and actions (or lack thereof) leading to violations justify dismissal of criminal charges as seen in prior rulings such as Tatad v. Sandiganbayan.
**Class Notes:**
1. **Right to Speedy Disposition (Art. III, Sec. 16, 1987 Constitution):** Ensures quick resolution in judicial, quasi-judicial, and administrative processes.
2. **Mandamus (Rule 65, Rules of Court):** To compel a performance of a ministerial duty, exceptions apply when gross abuse of discretion is evidenced.
3. **Prejudicial Conduct:** Unexplained and excessive delays violate fundamental legal protections leading to dismissal of charges in the interest of safeguarding constitutional rights.
4. **Relevant Case Law:** Provides substantial rulings like Tatad v. Sandiganbayan, Angchangco v. Ombudsman, and Abadia v. Court of Appeals emphasizing timely disposition of cases.
**Historical Background:**
The case highlights the inefficiencies in judicial processes during a period marked by administrative transitions and reorganizations post-EDSA Revolution. Reflects on persistent systemic inefficiencies spanning decades, emphasizing need for prompt judicial action to uphold constitutionally protected rights.
Leave a Reply