Yulo v People Facts: 1. Josefina Dimalanta and Lilany Yulo went to Myrna Roque. 2.

Dimalanta told Roque that Yulo is her BFF and that she is a good payer; and asked Roque if she can have Yulo's checks encashed. 3. Relying on this, she agreed. She received 3 checks from Yulo in return. However, such checks were dishonored later on since the account was already closed. 4. After failed demands, she finally filed a crim case against Yulo for violation of BP22 5. Yulo was found guilty beyond reasonable doubt in RTC. Yulo appealed to the CA, but the decision was affirmed in toto. 6. She filed an MR, but the MR was only resolved after 3 years after filing.(affirmed againt the decision in toto) Issues: WON the CA violated her right to speedy trial. NO Ratio 1. Sec 16 Art 3 of Bill of Rights: All persons shall have the right to a speedy disposition of their cases before all judicial, quasi judicial, or admin bodies under this provision, any party to a a case has the right to demand on all officials tasked with the administration of justice to expedite its disposition. However, the concept of speedy disposition is a relative term and must necessarily be a flexible concept. A mere mathematical reckoning of the time involved is not sufficient. In applying the Consti guarantee, particular regard must be taken of the facts and circumstances of each case. 2. The right to a speedy disposition of a case, like the right to speedy trial, is deemed violated only a) when the proceedings are attended by vexatious, capricious, and oppressive delays, or b) when unjustified postponements of the trial are asked for and secured, or c) when without cause or justifiable motive a long period of time is allowed to elapse without the party having his case tried. 3. The following factors must be considered: a) length of delay b) reasons for such delay c) assertion or failure to assert such right by the accused d) prejudice caused by the delay 4. In this case, the delay was sufficiently explained. The ponente retired during the pendency of the MR which was filed in March 1997. The case was assigned to Assoc Justice Dadole on Feb 2000. And then she resolved the motion within 2 weeks. Thus, there was no violation! (Not important) Issue: WON the CA erred in holding Yulo guilty beyond reasonable doubt. No 1. The elements were all proven (making or issuance of a check, knowledge that he has no/ insufficient funds, subsequent dishonor). 2. Findings of lower court and affirmed in toto by CA are entitled to great weight