Bill of Rights - Section 16 - Section 16 All persons shall...

Section 16. All persons shall have the right to a
speedy disposition of their cases before all judicial,
quasi-judicial, or administrative bodies.
Distinction between Section 14 and Section 16
While the rights of an accused only apply to the trial
phase of criminal cases, the right to a speedy disposition
of cases covers ALL phases of JUDICIAL, QUASI-
JUDICIAL or ADMINISTRATIVE proceedings.
Right to Speedy Disposition of Cases
 Raul H. Sesbreno has been a practicing lawyer
for over 30 years. The victim, Luciano
Amparado, was a porter of William Lines, Inc., a
shipping company also based in Cebu. Appellant
was found guilty the crime of murder
and sentencing him to reclusion perpetua, for
the death of one Luciano Amparado. He filed a
Motion To Quash Warrant of Arrest And/Or to
Grant Bail. The hearing did not push through
due to the fact that it was Saturday, and there
was no prosecutor available. The hearing on the
bail application was then reset. Subsequently,
the prosecution filed an Opposition to the Urgent
Application for Bail and presented both
testimonial and documentary evidence in
connection with the said Opposition. Later, the
trial court denied the application for
bail. Appellant alleges that his right to a speedy
disposition of his case was violated. Did the trial
court erred in denying the accused-appellant his
right to speedy trial and speedy disposition of
his case.
Answer: No. There is no showing that appellant raised
the issue of lack of notice of raffle at the earliest
opportunity. Appellant had willingly and actively
participated in these proceedings before the trial
court. By actively participating thereon, appellant is now
deemed estopped from complaining that the proceedings
were technically defective for want of a notice of the
raffle of his case. To say the least, appellants claim
comes too late to be of any merit. Also, there is no undue
delay of the bail hearings could be imputed, much less
persuasively shown, against appellee and the trial court.
People vs. Sesbreno
 The Ombudsman filed a case in the
Sandiganbayan against Mayor Binay of Makati
for Illegal Use of Public Funds and Violation of
Anti-Graft and Corrupt Practices Act. The
petitioner filed a motion to quash alleging that
the delay of more than 6 years constituted a
violation of his constitutional right of due process
which was subsequently denied and further, the
latter’s motion for reconsideration. In the
meantime, the prosecution filed a motion to
suspend the accused pendente lite (benefits)
which was later granted and ordered for a 90-
day suspension. A petition for certiorari was filed
by Mayor Binay in the SC praying that the denial
of his motion for reconsideration be set aside
and claims that he was denied of his rights when
the suspension was ordered even before he
could file his reply to the petitioner’s opposition.