Dacanay v. People
REITERATIONFacts
The Antecedents: In 1985, petitioner Jaime C. Dacanay was the vice-president of the National Sugar Trading Corporation (NASUTRA). In 1986, a criminal complaint for economic sabotage through smuggling, concerning the importation of raw sugar by NASUTRA in 1983 and 1984, was filed against principal officers, including petitioner. Procedural History: The Tanodbayan found sufficient prima facie evidence to file an information with the Sandiganbayan for violation of Section 3(e) of Republic Act No. 3019, as amended. Petitioner initially filed a motion to quash, which he later withdrew. Subsequently, prosecutors recommended dismissal for lack of evidence, but this was disapproved by higher officials. A motion to quash filed by a co-accused and adopted by petitioner was denied by the Sandiganbayan, as was a motion for reconsideration. Petitioner filed a motion for immediate and separate trial, invoking his right to speedy trial, which was opposed by the People of the Philippines. The Sandiganbayan denied this motion. A motion for reconsideration was also denied. The Petition: Petitioner filed a Petition for Review on Certiorari, treated as a petition under Rule 65 of the Revised Rules of Court, to set aside the Sandiganbayan's resolutions denying his motion for separate trial.
Issue(s)
Whether petitioner is entitled to a separate trial. Whether the denial of petitioner's motion for separate trial violated his constitutional right to speedy trial.
Ruling
The petition is impressed with merit. The Sandiganbayan is ORDERED to proceed with the trial of petitioner in Criminal Case No. 11957, separately if it need be.
Ratio Decidendi
On the entitlement to a separate trial: Section 8, Rule 119 of the 1985 Rules on Criminal Procedure explicitly states that jointly charged accused shall be tried jointly, unless the court in its discretion orders separate trials. The main objection of the respondent People of the Philippines to a separate trial was that it would entail repetitive presentation of evidence. However, the inconvenience and expense to the Government cannot be given preference over the constitutional right to speedy trial and the protection of a person's life, liberty, or property. This is particularly true when the opposition to the separate trial was based on the principal accused being abroad and not yet arrested; if an accused cannot be arrested due to being outside the territorial jurisdiction, then a co-accused under arrest should be more entitled to a separate trial. Furthermore, the principal accused has since returned and entered into a compromise agreement, strengthening the argument for a separate trial for petitioner. On the violation of the right to speedy trial: A separate trial is in consonance with the right to speedy trial guaranteed by the 1987 Constitution. A speedy trial is defined as one conducted according to law, free from vexatious, capricious, and oppressive delays, with the primordial purpose of preventing the oppression of an accused by indefinite delays and ensuring the prompt administration of justice. In this case, it has been eight years since the information was filed, and the case against petitioner has yet to be tried. This long delay has clearly prejudiced petitioner, who is now more than seventy-three years of age, thus violating his constitutional right.
Main Doctrine
The constitutional right to speedy trial and the protection of a person's life, liberty, or property outweigh the inconvenience and expense to the government in granting a separate trial, especially when the delay has prejudiced the accused.