Title
ABS-CBN Broadcasting Corporation vs. Office of the Ombudsman
Case
G.R. No. 133347
Decision Date
Apr 23, 2010
ABS-CBN and Lopez family alleged coercion in a 1973 agreement, accusing respondents of crimes. Ombudsman dismissed the case; SC upheld, citing ratification, death extinguishing liability, and no grave abuse of discretion.
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Case Digest (G.R. No. 133347)

Facts:

  1. Parties Involved:

    • Petitioners: ABS-CBN Broadcasting Corporation, Eugenio Lopez, Jr., Augusto Almeda-Lopez, and Oscar M. Lopez.
    • Respondents: Office of the Ombudsman, Roberto S. Benedicto, Exequiel B. Garcia, Miguel V. Gonzales, and Salvador (Buddy) Tan.
  2. Background of the Case:

    • Petitioners filed a criminal complaint against respondents for various violations under the Revised Penal Code (RPC), including execution of deeds by means of violence/intimidation, estafa, theft, robbery, usurpation of real property, and other deceits.
    • The Ombudsman dismissed the complaint for lack of probable cause.
    • Petitioners filed a petition for certiorari, which was dismissed by the Supreme Court, prompting them to file a Motion for Reconsideration.
  3. Key Events:

    • Petitioners alleged that respondents, particularly Roberto S. Benedicto, coerced them into signing a letter-agreement dated June 8, 1973, under duress.
    • Benedicto and Tan died during the pendency of the case, leading to their removal as respondents.
    • Petitioners argued that the ratification of the letter-agreement was irrelevant to determining criminal liability and that the criminal case should proceed even after the death of the accused to pursue civil liability.
  4. Legal Contentions:

    • Petitioners contended that the Ombudsman committed grave abuse of discretion in dismissing the criminal complaint.
    • They also argued that the case should be referred to the Court en banc due to novel legal questions, such as the relevance of ratification in criminal liability and the continuation of the case against deceased respondents.

Issue:

  1. Whether the ratification of the June 8, 1973 letter-agreement is relevant in determining the criminal liability of the respondents.
  2. Whether the criminal case should continue against deceased respondents (Benedicto and Tan) to pursue their civil liability.
  3. Whether the Ombudsman committed grave abuse of discretion in dismissing the criminal complaint for lack of probable cause.
  4. Whether the case presents novel questions of law warranting referral to the Court en banc.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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