A persons right to the speedy disposition of his case is guaranteed under Section 16,

Article III of the Philippine Constitution (Constitution) which provides:

Sec. 16. All persons shall have the right to speedy disposition of their cases before all
judicial, quasi-judicial, or administrative bodies.

This constitutional right is not limited to the accused in criminal proceedings buy
extends to all parties in all cases, be it civil or administrative in nature, as well as all
proceedings, either judicial or quasi-judicial. In this accord, any party to a case may
demand expeditious action to all officials who are tasked with the administration of
justice.
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Hence in the determination of whether the defendant has been denied his right to
a speedy disposition of a case, the following factors may be considered and balanced:
(1) length of delay; (2) reasons for the delay; (3) the assertion or failure to assert such
right by the accused; and (4) the prejudice caused by the delay. (Coscolluela vs
Sandiganbayan, G.R. No. 191411, July 15, 2013)

On Speedy Trial

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The right to a speedy trial may be defined as one free from vexatious, capricious and
oppressive delays, its salutary objective being assure that an innocent person may be free
from the anxiety and expense of a court litigation or, of otherwise, or having his guilt determined
within the shortest possible time compatible with the presentation and consideration of
whatsoever legitimate defense he may interpose.

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We emphasize that in determining the right of an accused to speedy trial, courts are
required to do more than a mathematical computation of the number of postponements of the
scheduled hearings of the case. A mere mathematical reckoning of the time involved is clearly
insufficient, and particular regard must be given to the facts and circumstance peculiar to each
case

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 The Court took into account the reasons for the delay, i.e. the frequent amendments of
procedural laws by presidential decrees, the structural reorganizations in existing prosecutorial
agencies and the creation of new ones by executive fiat, resulting in changes of personnel,
preliminary jurisdiction, and the function and powers of prosecuting agencies. The Court also
considered the failure of the accused to assert such right, and the lack of prejudice caused by
the delay to the accused.

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Right to Speedy trial and speedy disposition of case is violated only when the
proceeding is attended by vexatious, capricious and oppressive delays.

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In determining whether the [respondent] has been deprived of [her] right, factors to
consider and balances are the following: (1) length of delay; (2) reasons for the delay; (3) the
assertion or failure to assert such right by the accused; and (4) the prejudice caused by the
delay.

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The rights given to the accused by the Constitution and the Rules of Court are shields,
not weapons. Courts are tasked to give meaning to that intent. There being no capricious,
vexatious, oppressive delay in the proceedings, and no postponements unjustifiably sought,
[the right to speedy trial was not violated] (Tan vs. People, G.R. No. 173637, April 21, 2009)

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