FACTS:

Abelardo B. Licaros filed a Petition for Mandamus to compel the Sandiganbayan (First Division) to dismiss Criminal Case No. 6672, in which he is charged as an accessory to the robbery of the Legaspi City Branch of the Central Bank. The petitioner asserts that he was not involved in the planning or execution of the robbery, but instead reported the incident to the authorities, resulting in the recovery of a significant amount of the stolen money and the arrest of the principal accused.

Initially, the petitioner was granted a motion for discharge to be utilized as a state witness, but the Supreme Court later annulled it. The prosecution then filed a second motion for discharge, which was denied by the Sandiganbayan. As of March 8, 1983, the prosecution has presented ten witnesses.

During the trial, various witnesses testified, including NBI Agents Victor Bessat and Apollo Sayo, M/Sgt Raynero Galarosa, Sgt. Eliseo Rioveros, and CIS Agent Maria Corazon Pantorial. None of these witnesses implicated the petitioner in the robbery. The prosecution offered its documentary evidence, and the Sandiganbayan admitted and considered it, deeming the prosecution to have rested its case.

Later on, the Sandiganbayan allowed the prosecution's motion to reopen the case to present a witness on conspiracy, but it was established that the petitioner was not part of the conspiracy. The petitioner then filed a motion for separate trial, which was granted. He proceeded to present his evidence, including his own testimony and that of his father and other officials of the Central Bank, who testified that the petitioner's report broke the case and led to the recovery of the stolen money.

The petitioner filed his formal offer of exhibits and memorandum, praying for his acquittal. The Sandiganbayan admitted the exhibits and ordered the prosecution to file its reply memorandum. The case was considered submitted for decision, and both parties filed their reply memoranda.

However, the Sandiganbayan deferred the decision on the petitioner until after the submission of the case for decision regarding the other accused. The petitioner filed a motion for reconsideration, which was denied. As of the petition, the Sandiganbayan has not rendered a decision in the case, despite more than ten years passing since it was submitted for decision.

The petitioner, invoking his constitutional right to speedy justice, filed an omnibus motion to dismiss, but it has not been acted upon. The petitioner subsequently filed motions to resolve and for an early resolution, which the Sandiganbayan has still not granted.

ISSUES:

1. Did the Sandiganbayan violate the petitioner's right to a speedy disposition of his case?

2. Did the Sandiganbayan exceed the period mandated by law to decide the case?

3. Whether the inordinate delay in the disposition of a criminal case violates the accused's constitutional right to a speedy disposition of cases.

4. Whether the Sandiganbayan's failure to decide the case even after the lapse of more than ten years after it was submitted for decision violates the accused's right to a speedy disposition of his case.

5. Whether the accused waived or slept on his right to a speedy disposition.

6. Whether mandamus is an appropriate remedy to compel the performance of a public duty.

7. Whether the delay in the resolution of the criminal case violated the petitioner's constitutional right to a speedy disposition of his case.

RULING:

1. Yes, the Sandiganbayan violated the petitioner's right to a speedy disposition of his case.

2. Yes, the Sandiganbayan exceeded the period mandated by law to decide the case.

3. Yes, the inordinate delay in the disposition of a criminal case violates the accused's constitutional right to a speedy disposition of cases.

4. The Sandiganbayan's failure to decide the case violates the accused's right to a speedy disposition of his case.

5. The accused did not waive or sleep on his right to a speedy disposition.

6. Mandamus is a proper recourse to enforce a public right and compel the performance of a public duty, especially when mandated by the Constitution. It can be used to demand expeditious action from officials tasked with the administration of justice. While mandamus typically applies to ministerial duties, exceptions exist for cases involving gross abuse of discretion, manifest injustice, or palpable excess of authority. In this case, the inordinate delay in deciding the criminal case constituted a grave abuse of discretion and manifest injustice, justifying the issuance of the writ.

7. The dismissal of the criminal case against the petitioner is justified due to the 10-year delay in its resolution, which violated his constitutional right to a speedy disposition of his case. The delay caused vexation, oppression, and harm to the petitioner's personal and professional life. The petitioner did not contribute to the delay and consistently asserted his right. The Sandiganbayan failed to provide a valid reason for the delay and admitted that the case was among those that got "buried" during the reorganization. Additionally, the petitioner was charged as an accessory after the fact, further warranting the dismissal of the case.

PRINCIPLES:

• The right to a speedy disposition of a case is a constitutionally guaranteed right that finds greater significance in a criminal case.

• The failure to decide a case within the period prescribed by law, whether under PD 1606 or the Constitution, constitutes a violation of the right to a speedy disposition of a case.

• Justice delayed is justice denied. The principle emphasizes the importance of timely disposition of cases to prevent a denial of justice for the accused.

• An unreasonable delay in the disposition of a case violates the accused's constitutional rights, including the right to due process and the right to a speedy disposition of cases. (Tatad v. Sandiganbayan)

• The delay in resolving a case by the Ombudsman or any other prosecuting office violates the accused's constitutional right to a speedy disposition of cases. (Angchangco Jr. v. Ombudsman)

• The delay in resolving a case by the Office of the Ombudsman disregards its duty to act promptly on complaints and violates the accused's right to due process and to a speedy disposition of cases. (Roque v. Office of the Ombudsman)

• The accused's right to a speedy disposition of the case is not only violated when there is a delay on the part of the prosecution, but also when the court does not act promptly on the adjudication of the case within the period prescribed by law. (Abadia v. Court of Appeals)

• The breach of the accused's right to a speedy disposition of a case must be proven to be vexatious, capricious, and oppressive to justify the dismissal of the case.

• The right to a speedy disposition of a case is violated when there is unreasonable delay in the resolution or decision of the case.

• Factors that may be considered in determining the violation of the right to a speedy disposition include the length of delay, reasons for the delay, assertion or failure to assert the right by the accused, and prejudice caused by the delay.

• Silence or inaction by the accused does not amount to waiver of the right to a speedy disposition, especially if the accused has been persistent in demanding the resolution or decision of the case.

• Unjustified delay in the resolution or decision of a case can cause prejudice, distress, and anxiety to the accused.

• Mandamus is a proper remedy to enforce a public duty and guarantee a public right, especially when mandated by the Constitution.

• Exceptions to the rule that mandamus applies to ministerial duties exist in cases involving gross abuse of discretion, manifest injustice, or palpable excess of authority.

• The right to a speedy disposition of a case is guaranteed under the Constitution, and it is the duty of the court to expedite the resolution of cases.

• Delay in the resolution of a criminal case may violate the accused's constitutional right to a speedy disposition, justifying the dismissal of the case.

• An accused who did not contribute to the delay, consistently asserted their right, and was charged as an accessory after the fact may be entitled to the dismissal of the case.