MARIALEN C. CORPUZ Vs. THE
SANDIGANBAYAN
G.R. No. 162214 : November
11, 2014
FACTS:
The Ombudsman's office
released a Resolution citing reasonable cause against petitioners Antonio H.
Roman, Sr. and Marialen C. Corpuz, respectively, the President and
Vice-President of FILSYN Corporation, and many others. The complainants, as
well as Undersecretary of Finance Antonio P. Belicena and Petron Corporation
officials, were charged with violating Section 3 of Republic Act No. 2019 in
connection with the so-called tax credit racket. But apart from the above
situation, the Office of the Ombudsman has filed sixty-one related complaints
against fifty public authorities and private citizens in connection with the
issuing of tax credit certificates.
ISSUE:
Whether or not the accused has been deprived of
his right to a speedy disposition of the case and to a speedy trial.
RULING:
The right of the accused
to a speedy trial and a speedy resolution of the case against him was created
to discourage civilian persecution by suspending criminal proceedings for an
unlimited period of time, as well as to avoid disruptions in the administration
of justice by requiring courts to proceed with fair dispatch in criminal cases. Only where the proceeding is
accompanied by vexatious, capricious, and oppressive delays is the right to a
timely trial and a timely resolution of a lawsuit denied. The question of whether
or not an accused has been deprived such a right is not one that can be
answered with precision. The expression "fast disposition" is a
relative term that may be interpreted in a variety of ways.
In determining whether
the accused has been deprived of his right to a speedy disposition of the case
and to a speedy trial, four factors must be considered: (a) Length of delay; (b)
the reason for the delay; (c) the defendants assertion of his right; and (d)
prejudice to the defendant.
No less than Section 16
Artticle II of the 1987 Constitution provides that all persons shall have the
right to a speedy disposition of their cases before all judicial,
quasi-judicial or administrative bodies. The judicial bodies envisaged in the
said provision include the Office of the Ombudsman and the Office of the
Special Prosecutor. The petitioners, as well as the other defendants, were undoubtedly
prejudiced by the pause in the reinvestigation of the cases and the submission
of the Ombudsman/Special Prosecutor's opinion thereon. The state was as well.
The people have yet to show beyond a reasonable doubt that the petitioners are
guilty of the offences alleged. The court agreed with the Sandigan bayan's
decision that, before resorting to the harsh punishment of withdrawing the
cases without giving the complainant a chance to prove its argument, the
Sandigan bayan should request the Ombudsman/Special Prosecutor to clarify the
delay in submitting his opinion on his reinvestigation under penalty of
contempt.
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