Flores Vs. People (December 10, 1974)

Flores vs. People

GR L-25769 | December 10, 1974

FACTS:

Petitioners, Francisco Flores and Francisco Angel, were accused for robbery.  Information was filed in December 1951.  They were found guilty of the crime charged in November 1955.   Notice of appeal was file in December 1955.  It was until February 1958 that action was taken by CA—a resolution remanding the records of the case to the lower court for a rehearing of the testimony of a certain witness deemed material for the disposition of the case.  Such resolution was amended dated August 1959 which granted the petitioners to set aside the decision so that evidence for the defense on new facts may be received and a new decision in lieu of the old one may be rendered.  The case was returned to the lower court but nothing was done for about a year because the offended party failed to appear despite the 6/7 dates set for such hearing.  Furthermore, when the offended party took the witness stand, his testimony was characterized as a mere fiasco as he could no longer remember the details of the alleged crime and even failed to identify the 2 accused.

The trial court instead of rendering a decision sent back the records to the appellate tribunal.  5 more years elapsed without anything being done, petitioners sought dismissal of the case against them due to inordinate delay in the disposition (from December 1955- May 1965).  CA was unresponsive notwithstanding the vigorous plea of the petitioners, its last order being a denial of a second MR dated January 1966.  CA’s defense is that the case was not properly captioned as “People of the Philippines” and without “Court of Appeals” being made a party to the petition. 

ISSUE:  WON constitutional right to a speedy trial was violated.

HELD: YES.  Petition for certiorari was granted.  Orders denying Motion to dismiss as Motion to Reconsideration are set aside and nullified.   Criminal Case against petitioners was dismissed.

Constitutional right to a speedy trial means one free from vexatious, capricious and oppressive delays.  An accused is entitled to a trial at the earliest opportunity.  He cannot be oppressed by delaying the commencement of the trial for an unreasonable length of time.  The Constitution does not say that such right may be availed only where the prosecution of a crime is commenced and undertaken by the fiscal.  It does not exclude from its operation cases commenced by private individuals.  “Where a person is prosecuted criminally, he is entitled to a speedy trial, irrespective of the nature of the offense or the manner in which it is authorized to be commenced”. 

Technicalities should give way to the realities of the situation.  There should not be too much significance attached to the procedural defect (refer to CA’s defense).  CA failed to accord respect to this particular constitutional right amounting at the very least to a grave abuse of discretion.