Facts:

The case centers on ABS-CBN Broadcasting Corporation, its officers Eugenio Lopez, Jr., Augusto Almeda-Lopez, and Oscar M. Lopez as petitioners, against the Office of the Ombudsman and private respondents Roberto S. Benedicto, Exequiel B. Garcia, Miguel V. Gonzales, and Salvador (Buddy) Tan. The petition for certiorari arises from the Ombudsman's Joint Resolution dated May 2, 1997, which dismissed complaints filed by the petitioners against the private respondents. The historical backdrop of the case lies in the declaration of martial law in the Philippines by President Ferdinand Marcos in 1972, which led to the sequestration of numerous private corporations, including ABS-CBN.

The Lopezes’ allegations detailed events occurring immediately after the imposition of martial law. On September 22, 1972, military troops forcibly took over the ABS-CBN Broadcast Center in Quezon City, enforcing Letter of Instruction No. 1 that mandated the closure of all broadcast stations. Followin

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Facts:

Parties and Context

• Petitioners:
• ABS-CBN Broadcasting Corporation, represented by its officers Eugenio Lopez, Jr., Oscar Lopez, and Augusto Almeda-Lopez.
• Private Respondents:
• Roberto S. Benedicto
• Exequiel B. Garcia
• Miguel V. Gonzales
• Salvador (Buddy) Tan
• Context of Martial Law:
• The case emanates from the period following the declaration of martial law by President Ferdinand Marcos.
• Several private corporations, including ABS-CBN, were sequestered and their operations disrupted.

Events Leading to the Litigation

• Seizure and Closure of ABS-CBN Properties:
• On September 22, 1972, military troops seized the ABS-CBN Broadcast Center in Quezon City under LOI No. 1 issued by President Marcos.
• A total of seven (7) ABS-CBN television stations were closed down, and the company terminated its employees while providing retirement benefits.
• Proposal to Sell and Subsequent Detention:
• In November 1972, ABS-CBN, through its president Eugenio Lopez, Jr., proposed selling the network to the government.
• Shortly thereafter, Eugenio Lopez, Jr. was arrested and detained for almost five years until his eventual escape in 1977.
• Negotiations with Government-Connected Parties:
• Negotiations were initiated with Governor Benjamin “Kokoy” Romualdez regarding the potential acquisition of ABS-CBN, which did not materialize.
• On June 6, 1973, a fire at Kanlaon Broadcasting System (KBS) brought to the fore the issue of using ABS-CBN’s facilities.
• Through emissaries, notably Alfredo Montelibano (Chairperson of ABS-CBN’s Board), discussions were held with Roberto Benedicto regarding a temporary lease of the ABS-CBN studio facilities to RPN (Radio Philippines Network).
• Execution of the Letter-Agreement
• On June 8, 1973, a letter-agreement was executed wherein ABS-CBN leased its broadcast facilities to RPN.
• Key terms included the payment of monthly rentals (to be determined in further discussions with Benedicto) and provisions for the return of the leased facilities upon termination.
• Despite several subsequent meetings, a definitive monthly rental rate was not established.
• Subsequent Developments and Further Transactions
• Over the ensuing four months, negotiations to clarify the rental arrangement and even to discuss an outright sale continued intermittently.
• Formal attempts to resolve rental disputes were made by ABS-CBN’s counsels and executives, including a demand letter sent by Senator Lorenzo TaAada in May 1976.
• Gradually, control and management of the ABS-CBN terrestrial stations (both in Metro Manila and the provinces) were transferred to government entities such as the National Media Production Center (NMPC) and the Bureau of Broadcast.
• An inventory conducted in 1979–1980 and a later visit in 1984 revealed missing equipment and assets from the ABS-CBN premises.
• With the return of some assets in 1986 under President Corazon Aquino, ABS-CBN pursued civil claims relating to the disputed lease and rental payments.

Alleged Criminal Acts and Procedural History

• Crimes Charged (as alleged in the complaint-affidavits):
• Article 298 – Execution of Deeds by Means of Violence or Intimidation
• Article 315 (paragraphs 1[b], 2[a], 3[a]) – Estafa
• Article 308 – Theft
• Article 302 – Robbery
• Article 312 – Occupation of Real Property or Usurpation of Real Rights in Property
• Article 318 – Other Deceits
• Petitioners’ Allegations:
• The petitioners alleged that the lease agreement was not genuinely consensual but was executed under the shadow of coercion and deception by the respondents.
• They maintained that respondents, in conspiracy with other officers of KBS/RPN, intended to unlawfully take over ABS-CBN properties by disguising the takeover as a legitimate lease.
• Respondents’ Defense and Counter-Affidavits:
• Respondents denied the allegations, contending that the execution of the letter-agreement was a free and voluntary act by ABS-CBN.
• They argued that ABS-CBN’s own actions (e.g., pursuing discussions about rentals and subsequently claiming under the lease) ratified the transaction.
• They further invoked the authority granted under LOI No. 1-A, which legitimized the government's takeover of ABS-CBN properties.
• Procedural Actions Prior to the Decision
• The Ombudsman, after evaluating the complaint, issued a Joint Resolution dismissing the complaint-affidavits based on a lack of probable cause for the alleged crimes.
• The petitioners challenged this dismissal by filing a petition for certiorari under Rule 65, alleging grave abuse of discretion in the Ombudsman's resolution and reconsideration order.
• Matters concerning the death of two respondents (Benedicto and Tan) were raised, focusing on the implications for both criminal and civil liabilities.

Issue:

Sufficiency of the Alleged Probable Cause

• Whether the petitioners’ complaint-affidavits adequately established probable cause against the respondents for the crimes charged under the Revised Penal Code.

Validity of the Lease-Agreement

• Whether the lease executed on June 8, 1973, was tainted by coercion, intimidation, or fraudulent inducement that vitiated consent, thereby rendering it criminally suspect.

Ombudsman’s Discretion

• Whether the Ombudsman’s decision to dismiss the complaint-affidavits constituted a grave abuse of discretion, or if it was within the scope of his investigatory and prosecutorial powers.

Impact of Respondents’ Death on Liabilities

• Whether the death of respondents Roberto Benedicto and Salvador Tan extinguished both their criminal and civil liabilities, particularly in light of precedents like People v. Bayotas.
• Determination of the appropriateness of dropping deceased parties from the proceedings while allowing for separate civil actions.

Distinction Between Civil and Criminal Liability

• Whether the nature of the lease-agreement and the corresponding actions of the petitioners (such as demanding rental payments and subsequent claims) indicate that the issues were essentially civil rather than criminal.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)