People v. Sandiganbayan
REITERATIONFacts
The Antecedents: The Office of the Special Prosecutor (OSP) filed a Motion for Three Days Hearing Per Week to expedite the trial of Criminal Cases Nos. 26558, 26565, and 26905 before the Sandiganbayan (Special Division). Initially, the Sandiganbayan conducted hearings twice a week for three hours each day. A Resolution on February 26, 2002, ordered thrice-weekly hearings starting March 18, 2002, but this was not implemented due to the dismissal of private respondents' counsel and the appointment of new counsel de oficio. Subsequently, the parties agreed to extend hearing hours to five hours a day, twice a week (totaling ten hours per week), with Criminal Case No. 26558 and Criminal Case No. 26565 heard on Mondays, and Criminal Case No. 26905 heard on Wednesdays. This schedule was adopted by the Sandiganbayan via an Order on April 22, 2002, and consistently followed. Procedural History: The OSP filed a Motion for Three Days Hearing Per Week on March 21, 2003, seeking to implement the February 26, 2002 Resolution. The Sandiganbayan denied this motion on March 24, 2003. A motion for reconsideration was also denied on May 13, 2003. The OSP then filed a petition for certiorari and mandamus with the Supreme Court. The Petition: The OSP assailed the Sandiganbayan's denial of its motion for three days of hearing per week, arguing that the Sandiganbayan acted with grave abuse of discretion. The OSP contended that prior Supreme Court decisions mandated three-day-per-week hearings, that the cases involved national interest and detained accused, and that the private respondents had employed dilatory tactics.
Issue(s)
Whether the Sandiganbayan, Special Division, committed grave abuse of discretion amounting to lack or excess of jurisdiction in denying the Motion for Three Days Hearing Per Week and ordering two trial days per week instead of three; and whether the directive to "hear, try and decide with dispatch" removed the Sandiganbayan's discretion to schedule trials, violating Section 2, Rule 119 of the Rules of Court regarding continuous trial. Whether the Supreme Court should issue a writ of certiorari and mandamus to compel the Sandiganbayan to conduct three hearings per week, considering the interpretation of prior Supreme Court rulings and the discretion of the trial court in scheduling trial dates.
Ruling
The petition is devoid of merit. The Supreme Court dismissed the petition for certiorari and mandamus and affirmed the assailed Order dated March 24, 2003, and Resolution dated May 13, 2003, of the Sandiganbayan, Special Division.
Ratio Decidendi
On the issue of grave abuse of discretion and compliance with continuous trial: The Court reiterated that "grave abuse of discretion" signifies an arbitrary or despotic exercise of power due to passion, prejudice, or personal hostility, or a whimsical, arbitrary, or capricious exercise of power amounting to an evasion or refusal to perform a positive duty enjoined by law. For an act to be considered as such, the abuse of discretion must be patent and gross. The OSP failed to substantiate its charge of grave abuse of discretion against the Sandiganbayan. The Court held that the directive to "hear, try and decide with dispatch" did not remove the Sandiganbayan's discretion to schedule trials. The Court also granted the Sandiganbayan the power to promulgate its own rules, emphasizing its inherent power to control the trial of cases before it. The Court found no violation of Section 2, Rule 119 of the Rules of Court, which mandates continuous trial. The trial schedule adopted, allotting ten hours per week with the express consent of the OSP, satisfied the requirement of continuous trial. The Court noted that this schedule provided more hours per week than the proposed nine-hour schedule. On the issuance of mandamus, interpretation of prior rulings, and discretion of the trial court: The Court clarified that its previous rulings in A.M. No. 01-12-01-SC and A.M. No. SB-02-10-J, which mentioned the propriety of setting the plunder case for hearing three times a week, did not lay down an inexorable trial schedule. The issue in those cases was limited to administrative liability for setting hearings without prior consultation with defense counsel. The Court did not fix the number of hearing days per week for the Sandiganbayan. The Court emphasized that the determination of how many hearing days shall be devoted to trial rests within the sound discretion of the trial court. There is no justifiable reason to interfere with a trial court's scheduling of trial dates unless it clearly appears that the judge abused its power and that injustice has been done. The OSP failed to show such abuse or resulting injustice. The Court ruled that mandamus could not issue because the OSP had not sufficiently shown that the Sandiganbayan had an imperative duty to conduct three hearings per week. Mandamus compels the performance of a ministerial duty and does not lie to control or review the exercise of discretion, except in cases of grave abuse of discretion, manifest injustice, or palpable excess of authority, none of which were shown.
Main Doctrine
The determination of the number of hearing days for trial rests within the sound discretion of the trial court, and interference is warranted only upon a clear showing of grave abuse of discretion or resulting injustice. A schedule of ten hours per week, agreed upon by the parties, does not constitute grave abuse of discretion.