People v Tee GR No.

140546-47 (January 20, 2003)

"rights of the accused to speedy trial"
Facts
The case involves an automatic review of judgment made against Tee who was convicted
for illegal possession of marijuana and sentenced to death. The defense assailed the
decision of the court for taking admissible as evidence the marijuana seized from the
accused by virtue of allegedly general search warrant. They further contend that the
accused was deprived of his right to speedy trial by failure of the prosecution to produce
their witness who failed to appear during the 20 hearing dates thereby slowing down the
trial procedure.
Issue
Whether or not the substantive right of the accused for a speedy trial prejudiced during
the hearing of the case.
Held
The court ruled that the substantive right of the accused for a fair and speedy trial was
not violated. It held that the Speedy Trial Act of 1998 provides that the trial period for the
criminal cases should be in general 180 days. However, in determining the right of an
accused to speedy trial, courts should do more than a mathematical computation of the
number of postponements of the scheduled hearings of the case.The right to a speedy
trial is deemed violated only when: (1) the proceedings are attended by vexatious,
capricious, and oppressive delays; or (2) when unjustified postponements are asked for
and secured; or (3) when without cause or justifiable motive a long period of time is
allowed to elapse without the party having his case tried.
It was shown by the records that the prosecution exerted efforts in obtaining a warrant to
compel the witness to testify. The concept of speedy trial is necessarily relative where
several factors are weighed such as the length of time of delay, the reason of such delay,
and conduct of prosecution and the accused and the prejudice and damaged caused to
the accused of such delay. The court did not find the 20 days of delayed hearing
unreasonable length of time as to constitute deprivation of the constitutional rights of the
accused for a speedy trial in addition to the fact that court trial may be always subjected
to postponement for reasonable cause of delay. In the absence of showing that the reason
for delay was capricious or oppressive, the State must not be deprived of reasonable
opportunity in prosecuting the accused.