FACTS:

Amando A. Inocentes and four others were charged with violating Section 3(e) of Republic Act (R.A.) No. 3019. Inocentes, as the Branch Manager of the GSIS Tarlac City Field Office, was accused of conspiring with others to give undue preference and grant loans to unqualified borrowers outside the jurisdiction of the Tarlac City Field Office. Inocentes filed an omnibus motion to quash, asserting that the information was defective, there was no evidence of his cooperation or conspiracy, the Sandiganbayan lacked jurisdiction, and his right to speedy disposition was violated. The Sandiganbayan denied the motion, stating that jurisdiction was proper, the information was sufficient, and the delay was excusable. Inocentes filed a motion for reconsideration, reiterating his arguments and mentioning the dismissal of the estafa case related to the same transactions. The Sandiganbayan denied the motion, clarifying that the dismissal of the estafa case did not affect the present case. Inocentes then brought a petition before the Supreme Court, asserting that the evidence presented did not meet the standard of probable cause. The OSP countered, arguing that Inocentes sought absolution without going through trial. Both the OSP and the Office of the Solicitor General submitted their comments, with the OSP supporting probable cause and the Solicitor General deferring to the OSP.

ISSUES:

1. Whether the Sandiganbayan committed grave abuse of discretion in denying Inocentes' omnibus motion.

2. Whether the Sandiganbayan committed grave abuse of discretion in denying the motion to quash the information.

3. Whether the informations filed against the accused are valid for providing the necessary material allegations of the charges.

4. Whether the Sandiganbayan has jurisdiction over the accused despite his position not having a salary grade of 27.

5. Whether the finding of probable cause by the Sandiganbayan can be questioned by the accused.

6. Whether the Sandiganbayan acquired jurisdiction over the person of the accused.

7. Whether the Office of the Ombudsman violated the accused's constitutional right to a speedy disposition of the case.

8. Whether the delay in resolving the criminal case violated the accused's right to due process and speedy disposition of cases.

RULING:

1. The Sandiganbayan did not commit grave abuse of discretion in denying Inocentes' omnibus motion or the motion to quash the information.

2. The informations filed against the accused are valid because they adequately provide the material allegations to apprise him of the nature and cause of the charge.

3. The Sandiganbayan has jurisdiction over the accused because he held a position as the branch manager of a government-owned or -controlled corporation, which falls within the coverage of the Sandiganbayan's jurisdiction, regardless of the salary grade.

4. The finding of probable cause by the Sandiganbayan cannot be questioned by the accused since he voluntarily surrendered to the jurisdiction of the court and posted bail.

5. The Sandiganbayan acquired jurisdiction over the person of the accused upon his voluntary appearance and posting of bail. The accused cannot claim exemption from the court's jurisdiction by questioning the validity of the warrant of arrest after voluntarily submitting himself to the jurisdiction of the court.

6. The Office of the Ombudsman violated the accused's constitutional right to due process and to a speedy disposition of the case. The delay of seven years in resolving the criminal charges against the accused constituted a violation of his constitutional rights as well as the Ombudsman's constitutional duty to act promptly on complaints filed before it.

7. Yes, the delay in resolving the criminal case violated the accused's right to due process and speedy disposition of cases. The Court held that the period of six years for the transfer of records from the trial court to the Sandiganbayan already constitutes an inordinate delay. The accused cannot be blamed for the delay as the intervals between his motions were miniscule compared to the transfer of records. Moreover, the accused cannot be faulted for not invoking his right to a speedy disposition of his case when he was unaware that the investigation against him was still ongoing. The Office of the Ombudsman failed to present any plausible reason for the delay, and it was its responsibility to expedite the case within a reasonable time. The Court found that the delay of at least seven years before the filing of the informations prejudiced the accused's defense. Therefore, the Sandiganbayan is ordered to dismiss the case against the accused.

PRINCIPLES:

• The Constitution empowers the courts to determine whether there has been a grave abuse of discretion amounting to lack or excess of jurisdiction.

• Grave abuse of discretion is a circumstance beyond the legal error committed by a decision-making agency or entity and affects even the authority to render judgment.

• The extraordinary writ of certiorari is used to address lower court actions rendered without or in excess of jurisdiction or with grave abuse of discretion amounting to lack of jurisdiction.

• Conspiracy can be charged as a crime or as a mode of committing a crime.

• When conspiracy is charged as a crime, the act of conspiring and all the elements must be set forth in the information.

• When conspiracy is considered as a mode of committing the crime, there is less necessity of reciting its particularities in the information because conspiracy is not the gravamen of the offense charged.

• It is enough that the indictment contains a statement of facts relied upon to be constitutive of the offense in ordinary and concise language, with as much certainty as the nature of the case will admit, in a manner that can enable a person of common understanding to know what is intended, and with such precision that the accused may plead his acquittal or conviction to a subsequent indictment based on the same facts.

• The jurisdiction of the Sandiganbayan is determined by the position held, not the salary grade of the accused.

• The Sandiganbayan maintains its jurisdiction over officials specifically enumerated in the law, regardless of their salary grades.

• Even low-level management positions fall under the jurisdiction of the Sandiganbayan.

• The judge's determination of probable cause is limited to deciding whether an arrest warrant should be issued against the accused, and should not override the public prosecutor's determination of probable cause, unless the information is invalid on its face or there is manifest error or grave abuse of discretion.

• Jurisdiction over the person of the accused is acquired upon his arrest or apprehension, with or without a warrant, or his voluntary appearance or submission to the jurisdiction of the court.

• The giving or posting of bail by the accused is tantamount to submission of his person to the jurisdiction of the court.

• The right to a speedy disposition of a case is guaranteed under the Constitution, and it extends to all parties in all cases, be it civil or administrative in nature.

• The delay in the termination of preliminary investigation or the resolution of the case violates the accused's constitutional right to due process and the constitutional guarantee to a speedy disposition of cases.

• The accused has the right to due process and speedy disposition of cases.

• Inordinate delay in resolving a criminal case violates the accused's right to due process and speedy disposition of cases.

• The accused cannot be faulted for the delay in the resolution of his case when he was unaware that the investigation against him was still ongoing.

• It is the responsibility of the Office of the Ombudsman to expedite the prosecution of a case within a reasonable time.