Imperial v. Joson

Case Title: Imperial vs. Joson, 635 SCRA 71, G.R. NO.
160067 Date: November 17, 2010
Rule: RULE 119 – Trial; The Speedy Trial Act/RA 8493 as amended by OCA Ponente: DEL CASTILLO, J.:
Circular No. 101-2017
Revised Guidelines for Continuous Trial of Criminal Cases
A.M. No. 15-06-10-SC, effective September 1, 2017
Topic: SPEEDY TRIAL
Doctrine:
In determining whether the accused has been deprived of his right to a speedy disposition of the case and to a
speedy trial, four factors must be considered: (a) length of delay; (b) the reason for the delay; (c) the
defendant’s assertion of his right; and (d) prejudice to the defendant." xxxx
Although the Revised Rules of Criminal Procedure concededly mandates commencement of the trial within 30
days from receipt of the pre-trial order and the continuous conduct thereof for a period not exceeding 180
days, Section 3 a (1), Rule 119 provides that delays resulting from extraordinary remedies against
interlocutory orders shall be excluded in computing the time within which trial must commence. In
determining the right of an accused to speedy trial, moreover, courts are "required to do more than a
mathematical computation of the number of postponements of the scheduled hearings of the case" and to
give particular regard to the facts and circumstances peculiar to each case. Viewed in the context of the above
discussed procedural antecedents as well as the further reassignment of the case to Prosecutor Baligod as a
consequence of Prosecutor Sia’s subsequent transfer to another government office, we find that the CA
correctly brushed aside petitioner Francisco's claim that the postponements of the pre-trial conferences in the
case before the Sariaya MTC were violative of his right to a speedy trial.
Facts:
A vehicular accident in 2001 led to legal proceedings, including a criminal case and civil cases between parties
involved. The cases spanned multiple courts, resulting in issues of litis pendentia and conflicting jurisdiction.
Throughout the proceedings, there were various motions, amendments, and disputes, leading to appeals and
petitions.
petitioners Francisco and Imperial essentially fault the CA for upholding the jurisdiction of the Parañaque RTC over
the Naga RTC with respect to the parties’ causes of action for damages against each other. Calling attention to the
lesser case load of the Naga RTC, petitioners argue that the cause for the just, speedy and inexpensive disposition
of the case will not be served by the Parañaque RTC. Despite said court’s relative proximity to majority of the
parties, petitioners likewise maintain that majority of the witnesses material to the complete disposition of the
case live closer to the Naga RTC. They alleged a violation of the right to a speedy trial in a criminal case, and also
claiming capricious delays in pre-trial conferences. Despite the petitioner's contentions, the Court of Appeals
upheld the trial court's decisions. Concurrently, other civil cases involving third-party complaints and pre-trial
conferences faced similar complexities.
The parties filed petitions for review on certiorari, seeking relief and clarification on legal issues. The cases were
consolidated for Supreme Court review, with the rule of speedy trial being a central concern in one of the
petitions.
Issue:
Whether the right of the petitioners for speedy trial of their cases was violated.
Ruling
NO. "While justice is administered with dispatch, the essential ingredient is orderly, expeditious and not mere
speed. It cannot be definitely said how long is too long in a system where justice is supposed to be swift, but
deliberate. It is consistent with delays and depends upon circumstances. It secures rights to the accused, but it
does not preclude the rights of public justice. Also, it must be borne in mind that the rights given to the accused by
the Constitution and the Rules of Court are shields, not weapons; hence, courts are to give meaning to that intent.
A balancing test of applying societal interests and the rights of the accused necessarily compels the court to
approach speedy trial cases on an ad hoc basis.
In determining whether the accused has been deprived of his right to a speedy disposition of the case and to a
speedy trial, four factors must be considered: (a) length of delay; (b) the reason for the delay; (c) the defendant’s
assertion of his right; and (d) prejudice to the defendant." xxxx
xxx
Although the Revised Rules of Criminal Procedure concededly mandates commencement of the trial within 30 days
from receipt of the pre-trial order and the continuous conduct thereof for a period not exceeding 180 days,
Section 3 a (1), Rule 119 provides that delays resulting from extraordinary remedies against interlocutory orders
shall be excluded in computing the time within which trial must commence. In determining the right of an accused
to speedy trial, moreover, courts are "required to do more than a mathematical computation of the number of
postponements of the scheduled hearings of the case" and to give particular regard to the facts and circumstances
peculiar to each case. Viewed in the context of the above discussed procedural antecedents as well as the further
reassignment of the case to Prosecutor Baligod as a consequence of Prosecutor Sia’s subsequent transfer to
another government office, we find that the CA correctly brushed aside petitioner Francisco's claim that the
postponements of the pre-trial conferences in the case before the Sariaya MTC were violative of his right to a
speedy trial.

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Case Title: Imperial vs. Joson, 635 SCRA 71, G.R. NO.

160067 Date: November 17, 2010

Topic: SPEEDY TRIAL

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