Facts:

The case involves a petition for certiorari filed by ABS-CBN Broadcasting Corporation and its officers, Eugenio Lopez, Jr., Augusto Almeda-Lopez, and Oscar M. Lopez, against the Office of the Ombudsman and private respondents Roberto S. Benedicto, Exequiel B. Garcia, Miguel V. Gonzales, and Salvador (Buddy) Tan. The petition was decided on October 15, 2008, by the Supreme Court of the Philippines. The case traces back to the declaration of martial law by President Ferdinand Marcos on September 21, 1972, which led to the closure and sequestration of several private corporations, including ABS-CBN. Following the declaration, military troops seized the ABS-CBN Broadcast Center in Quezon City, citing Letter of Instruction No. 1, which mandated the closure of all media outlets.

In April 1994, the Lopezes filed complaint-affidavits against the private respondents, alleging various crimes under the Revised Penal Code, including execution of deeds by violence, estafa, theft, robbe...

Facts:

Background and Sequestration of ABS-CBN

• This case arises from the declaration of martial law by President Ferdinand Marcos on September 21, 1972, and the subsequent sequestration of ABS-CBN Broadcasting Corporation (ABS-CBN) by the government.
• On September 22, 1972, military troops enforced the closure of ABS-CBN’s broadcast center in Quezon City under Letter of Instruction (LOI) No. 1.
• ABS-CBN terminated its employees on October 31, 1972, and offered retirement benefits.

Negotiations and Lease Agreement

• In November 1972, Eugenio Lopez, Jr., ABS-CBN’s president, proposed selling the company to the government, which did not materialize.
• In 1973, ABS-CBN negotiated with Benjamin “Kokoy” Romualdez, but no sale occurred.
• On June 6, 1973, the Kanlaon Broadcasting System (KBS), managed by Roberto S. Benedicto, was destroyed by fire. Benedicto requested to temporarily use ABS-CBN’s facilities to operate TV Channel 9.
• On June 8, 1973, ABS-CBN and KBS entered into a lease agreement for ABS-CBN’s facilities, with the understanding that KBS would pay reasonable rental fees. However, no rental payments were made.

Post-Lease Developments

• In 1974, KBS was authorized by the Department of National Defense to use ABS-CBN’s provincial stations.
• Between 1980-1986, ABS-CBN’s properties were transferred to the National Media Production Center (NMPC) and other government entities.
• In 1986, President Corazon Aquino returned ABS-CBN’s stations to the company.

Filing of Criminal Complaints

• In April 1994, ABS-CBN filed a complaint against Benedicto and others for crimes including estafa, theft, robbery, and usurpation of real property.
• The Office of the Ombudsman dismissed the complaint in 1997, finding no probable cause.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Ombudsman’s Discretion: The Ombudsman has broad investigatory and prosecutory powers under the Constitution. Courts do not interfere unless there is grave abuse of discretion, which was not proven in this case.
2. Validity of Lease Agreement: The lease agreement between ABS-CBN and KBS was valid and consensual. ABS-CBN’s subsequent actions, including claims for rentals and ratification of the agreement, undermined their argument that the agreement was forced.
3. Criminal vs. Civil Liability: The allegations against the respondents pertained to a civil contractual dispute, not criminal acts. The Ombudsman correctly dismissed the criminal complaints.
4. Survival of Civil Liability: While civil liability ex delicto (arising from criminal acts) was extinguished by the respondents’ deaths, civil liability based on other sources (e.g., contract) could still be pursued through a separate civil action, as petitioners have done by filing a claim against Benedicto’s estate.