G.R. No. 75112 - Filamer Christian Institute vs. Court of Appeals

Petitioner Leticia B. Agbayani and respondent Loida Marcelina J. Genabe were both employees of the Regional Trial Court (RTC), Branch 275, Las Piñas City, holding the positions of Court Stenographer and Legal Researcher II, respectively.

On December 29, 2006, Agbayani filed a criminal complaint for grave oral defamation against Genabe, docketed as I.S. No. 07-0013 before the City Prosecutor of Las Piñas City.
The complaint alleged that Genabe uttered defamatory statements against Agbayani in the presence of their co-employees during work. The alleged statements included belittling remarks and accusations such as "Nagbebenta ka ng kaso, tirador ka ng judge" and "Sige high blood din ka, mamatay ka sana sa high blood mo."

On February 12, 2007, the City Prosecutor found probable cause to file information for grave oral defamation against Genabe.

Genabe filed a petition for review with the DOJ undersecretary Ernesto L. Pineda.
The DOJ reversed the City Prosecutor’s finding, holding that Genabe’s utterances constituted only slight oral defamation. The statements were uttered in the heat of anger amid provocation by Agbayani.
The DOJ further dismissed the case for failure to comply with the mandatory Barangay conciliation process under the Local Government Code (RA 7160), as the parties were residents of Las Piñas City and the incident occurred at their workplace.
The DOJ directed the City Prosecutor to move for withdrawal of the information against Genabe.

Agbayani filed a motion for reconsideration at the DOJ which was denied on June 25, 2007.
She then filed a petition for certiorari before the CA alleging grave abuse of discretion by the DOJ. She contended that the DOJ did not observe procedural requirements mandated by DOJ Circular No. 70 (2000 NPS Rules on Appeal) and that probable cause existed for grave oral defamation.
On March 27, 2008, the CA dismissed the petition, affirming the DOJ’s findings and ruling. The motion for reconsideration was also denied on July 3, 2008.

The DOJ’s reversal of the City Prosecutor’s resolution was a grave abuse of discretion.
The downgrade of the offense to slight oral defamation was erroneous.
The dismissal based on non-compliance with the Local Government Code mandatory Barangay conciliation was improper.
The DOJ failed to strictly apply its procedural rules under Circular No. 70 in allowing Genabe’s petition for review despite irregularities.

Whether the DOJ committed grave abuse of discretion when it reversed the finding of probable cause for grave oral defamation and downgraded the offense to slight oral defamation.
Whether the DOJ correctly dismissed the complaint due to non-compliance with the mandatory Barangay conciliation process under the Local Government Code of 1991 (RA 7160).
Whether the DOJ erred in accepting and considering Genabe’s petition for review despite alleged non-compliance with the procedural requirements of DOJ Circular No. 70, particularly regarding filing, attachments, and service of petitions.
Whether the CA committed reversible error in affirming the DOJ’s findings and denial of the petition for certiorari.