Facts:

The case involves petitioners ABS-CBN Broadcasting Corporation and its officers, Eugenio Lopez, Jr., Augusto Almeda-Lopez, and Oscar M. Lopez, against the Office of the Ombudsman and several respondents, including Roberto S. Benedicto, Exequiel B. Garcia, Miguel V. Gonzales, and Salvador (Buddy) Tan. The events leading to this case began with a criminal complaint filed by the petitioners against the respondents for various violations of the Revised Penal Code, including execution of deeds by means of violence or intimidation, estafa, theft, robbery, usurpation of real property, and other deceits. The complaint stemmed from allegations that the respondents, particularly Benedicto, had illegally taken control of ABS-CBN's assets and facilities during the Marcos regime. The Ombudsman dismissed the complaint for lack of probable cause, leading to the petitioners filing a certiorari petition with the Supreme Court. The Supreme Court, in its decision dated April 23, 2010, uphel...

Facts:

Background of the Case

• Petitioners involved ABS-CBN Broadcasting Corporation and its officers Eugenio Lopez, Jr., Augusto Almeda-Lopez, and Oscar Lopez.
• They filed a Motion for Reconsideration challenging a prior Decision (G.R. No. 133347) that dismissed their petition for certiorari.
• The original petition sought to question the Ombudsman’s Resolution which found no probable cause to indict several respondents for multiple violations under the Revised Penal Code (RPC), including offenses under Articles 298 (Execution of Deeds by Means of Violence or Intimidation), 315 (Estafa), 308 (Theft), 302 (Robbery), 312 (Occupation of Real Property or Usurpation of Real Rights in Property), and 318 (Other Deceits).

Procedural History and Allegations

• The petitioners argued that:
• The letter-agreement dated 8 June 1973, which was purportedly signed under coercion, is irrelevant to determining criminal liability.
• Despite the death of some respondents, specifically Roberto S. Benedicto and Salvador (Buddy) Tan, criminal complaints should not be terminated since the same facts could ground civil liability.
• Petitioners further requested the case be referred to the Court en banc, asserting the presence of novel legal questions, specifically:
• Whether the civil law principle of ratification has any bearing on ascertaining criminal liability.
• Whether criminal cases may continue against parties who have died insofar as the alleged civil liability remains actionable.
• The petitioners’ complaint-affidavits contained allegations involving meetings held in 1976, purportedly showing improper conduct by respondents in relation to the unauthorized takeover and management of ABS-CBN assets.

Facts Pertaining to the Letter-Agreement and Its Implications

• Petitioners claimed that the execution of the letter-agreement was by means of violence or intimidation (as required under Article 298 of the RPC).
• They contended that they were forced to sign the letter, yet subsequently acted in accordance with its terms by pursuing rentals, thereby effectively ratifying the agreement.
• The letter-agreement’s relevance was challenged by petitioners as immaterial in determining respondents’ criminal liability.

Respondents’ Status and Dismissal Issues

• Respondents named include the Office of the Ombudsman, Roberto S. Benedicto, Exequiel B. Garcia, Miguel V. Gonzales, and Salvador Tan.
• The assailed Decision had already dropped respondents Benedicto and Tan due to their deaths, citing earlier rulings in People v. Bayotas and Benedicto v. Court of Appeals.
• Later developments revealed that respondent Miguel V. Gonzales was also reported dead, necessitating his dismissal from the case.

Arguments Presented on Reconsideration

• Petitioners maintained that the ratification issue is irrelevant for criminal liability as it is a civil law concept.
• They contended that even if respondents were dead during the pendency, the issues regarding civil liability arising from the same act remain actionable separately.
• They invoked provisions of the Rules of Court regarding claims against a decedent's estate, arguing that dismissing the criminal complaint should not preclude pursuing civil recovery for alleged contractual breaches.

Issue:

Materiality of the Letter-Agreement

• Whether the execution and validity of the letter-agreement dated 8 June 1973 is relevant or material in establishing the criminal liability of the respondents, especially regarding alleged coercion under Article 298 of the RPC.

Appropriate Disposition of Cases Involving Deceased Respondents

• Whether respondents who have died (specifically Roberto S. Benedicto, Salvador Tan, and later Miguel V. Gonzales) should be maintained as parties in the criminal proceedings, or if their death necessitates dismissal of the criminal charges.

Claim of Grave Abuse of Discretion by the Ombudsman

• Whether the Ombudsman committed grave abuse of discretion when he dismissed the criminal complaint for lack of probable cause, in light of the petitioners’ complaint-affidavits alleging criminal acts.

Distinction and Separation Between Criminal and Civil Liability

• Whether a criminal complaint may continue to exist independently of a civil action, particularly when the alleged conduct gives rise to both criminal charges and a separate civil remedy under specific rules governing claims against a decedent’s estate.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)