SECTION 14 – RIGHTS OF THE ACCUSEDCRIMINAL DUE PROCESSTATAD VS. SANDIGANBAYAN(G.R. Nos. 72335-39. March 21, 1988)YAP, J:Facts: October 1974, Antonio de los Reyes, former Head Executive Assistant of the thenDepartment of Public Information (DPI) and Assistant Officer-in-Charge of the Bureau ofBroadcasts, filed a formal report with the Legal Panel, Presidential Security Command (PSC),charging petitioner, who was then Secretary and Head of the Department of Public Information,with alleged violations ofRepublic Act No. 3019, otherwise known asthe Anti-Graft and CorruptPractices Act. Apparently, no action was taken on said report. Then, in October 1979, or fiveyears later, it became publicly known that petitioner had submitted his resignation as Minister ofPublic Information, and two months after, or on December 12, 1979, Antonio de los Reyes filed acomplaint with the Tanodbayan (TBP Case No. 8005-16-07) against the petitioner, accusing himof graft and corrupt practices in the conduct of his office as then Secretary of Public Information.The complaint repeated the charges embodied in the previous report filed by complainantbefore the Legal Panel, Presidential Security Command (PSC). On January 26, 1980, theresignation of petitioner was accepted by President Ferdinand E. Marcos. On April 1, 1980, theTanodbayan referred the complaint of Antonio de los Reyes to the Criminal Investigation Service(CIS) for fact-finding investigation. On June 16, 1980, Roberto P. Dizon, CIS Investigator of theInvestigation and Legal Panel, PSC, submitted his Investigation Report, with the followingconclusion, ". . . evidence gathered indicates that former Min. TATAD had violated Sec. 3 (e) andSec. 7 ofRA 3019, respectively. On the other hand, Mr. ANTONIO L. CANTERO is also liable underSec. 5 ofRA 3019," and recommended appropriate legal action on the matter. Petitioner claimsthat the Tanodbayan culpably violated the constitutional mandate of "due process" and "speedydisposition of cases" in unduly prolonging the termination of the preliminary investigation and infiling the corresponding information’s only after more than a decade from the allegedcommission of the purported offenses, which amounted to loss of jurisdiction and authority tofile the information’s.Issue: Whether or not the petitioner was deprived of his constitutional right to due process andthe right to "speedy disposition" of the cases against him as guaranteed by the ConstitutionHeld: YES. The Court find the long delay in the termination of the preliminary investigation bythe Tanodbayan in the instant case to be violative of the constitutional right of the accused todue process.Substantial adherence to the requirements of the law governing the conduct ofpreliminary investigation, including substantial compliance with the time limitation prescribed bythe law for the resolution of the case by the prosecutor, is part of the procedural due processconstitutionally guaranteed by the fundamental law. Not only under the broad umbrella of the
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