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Flores vs People Yes.

The constitutional right to a speedy trial

means one free from vexatious, capricious and
FACTS: oppressive delays. Thus, if the person accused were
The accusation for robbery against petitioners
innocent, he may within the shortest time possible be
Francisco Flores and Francisco Angel was filed as far back
as December 31, 1951. They were found guilty on spared from anxiety and apprehension arising from a
November 29, 1955. The notice of appeal was filed on prosecution, and if culpable, he will not be kept long in
December 8, 1955. For a period of three years, until suspense as to the fate in store for him, within a period
February 10, 1958, no action was taken by the Court of of course compatible with his opportunity to present any
Appeals. It was until February 1958 that action was taken valid defense. The remedy in the event of a non-
by CA—a resolution remanding the records of the case observance of this right is by habeas corpus if the
to the lower court for a rehearing of the testimony of a
accused were restrained of his liberty, or by certiorari,
certain witness deemed material for the disposition of
the case. Such resolution was amended dated August prohibition, or mandamus for the final dismissal of the
1959 which granted the petitioners to set aside the case. Also, where a prosecuting officer, without good
decision so that evidence for the defense on new facts cause, secures postponements of the trial of a defendant
may be received and a new decision in lieu of the old one against his protest beyond a reasonable period of time,
may be rendered. Accordingly, the case was returned to as in this instance for more than a year, the accused is
the lower court with the former decision set aside but entitled to relief by a proceeding in mandamus to compel
nothing was done for about a year because the offended
a dismissal of the information, or if he be restrained of
party failed to appear six or seven dates set for such
hearing. When the offended party took the witness his liberty, by habeas corpus to obtain his freedom.
stand, his testimony was far from satisfactory,
characterized as a mere "fiasco" as he could no longer Not too much significance should be attached to
remember the details of the alleged crime, there was the procedural defect pointed out in the answer of the
even a failure to identify the two accused. Instead of People of the Philippines that the Court of Appeals
rendering a new decision, the former one having been should have been made the party respondent. What
set aside as required by the Court of Appeals, the lower cannot be sanctioned was its failure to accord respect to
court merely sent back the records to the appellate this particular constitutional right. It did amount at the
tribunal. very least to a grave abuse of discretion. Whatever
deficiency in the pleading may then be singled out, it
Five more years having elapsed without anything cannot obscure the obvious disregard of one of the most
being done, petitioners sought the dismissal of the cases important safeguards granted an accused. To deny
against them due to such inordinate delay in their petitioners the remedy sought would be to exalt form
disposition, which covered the period of December 8, over substance. At any rate, the petition could be
1955 to May 10, 1965, a period of almost a decade; thus considered, and rightly so, as being directed at the Court
did they invoke their constitutional right to a speedy of Appeals.This is one of those situations then where, in
trial. Respondent Court of Appeals was unresponsive. In the apt language of the then Justice, now Chief Justice,
the answer on behalf of the People of the Philippines, the Makalintal, "technicalities should give way to the
facts as above set forth were substantially admitted. realities of the situation." The Court ordered that the
However, a special and affirmative defense raised was criminal case against petitioners be dismissed.
that the case was not properly captioned, as the People
of the Philippines, against whom it is filed, is not a
tribunal or an office exercising Judicial functions and that
without the Court of Appeals being made a party to the
petition, it cannot be said that it stated facts sufficient to
constitute a cause of action

Whether or not the right to speedy trial of
petitioners were violated.