Facts:

The case involves Leticia B. Agbayani (petitioner) and Loida Marcelina J. Genabe (respondent), both employees of the Regional Trial Court (RTC), Branch 275 in Las Piñas City. On December 29, 2006, Agbayani filed a criminal complaint for grave oral defamation against Genabe, alleging that Genabe made derogatory remarks about her in front of their colleagues while she was performing her duties. The statements included accusations of incompetence and unprofessional behavior, suggesting that Agbayani was "feeling lawyer" and insinuating that she was selling cases. The complaint was initially found to have probable cause by the Office of the City Prosecutor of Las Piñas City on February 12, 2007. However, Genabe filed a petition for review with the Department of Justice (DOJ), which led to a reversal of the initial finding. The DOJ concluded that the remarks constituted only slight oral defamation, made in the heat of anger, and noted that the complaint had not undergone...

Facts:

Background of the Parties and Workplace

• Petitioner Leticia B. Agbayani and respondent Loida Marcelina J. Genabe were both employees of the Regional Trial Court (RTC), Branch 275 in Las PiAas City.
• Agbayani held the position of Court Stenographer while Genabe was employed as Legal Researcher II.

The Complaint for Grave Oral Defamation

• On December 29, 2006, Agbayani filed a criminal complaint for grave oral defamation against Genabe at the Office of the City Prosecutor of Las PiAas City (docketed as I.S. No. 07-0013).
• The complaint alleged that Genabe, in the presence of fellow court employees and during the normal course of duty, uttered defamatory statements such as:

- “ANG GALING MO LETY…” - “FEELING LAWYER KA KASI…” - “STENOGRAPHER KA MAGSTENO KA NA LANG…” - And similar derogatory remarks implying that Genabe was acting beyond her proper role.

Preliminary Investigation and Findings by the City Prosecutor

• In a Resolution dated February 12, 2007, the Office of the City Prosecutor of Las PiAas City found probable cause to file an Information for grave oral defamation against Genabe.
• This resolution was later subject to review following procedural and substantive disputes raised by both parties.

Intervention by the Department of Justice (DOJ)

• Upon filing of a petition for review by respondent Genabe, DOJ Undersecretary Ernesto L. Pineda re-evaluated the findings.
• The DOJ found merit in Genabe’s petition, determining that the utterances amounted only to slight oral defamation because:

- The words were allegedly spoken in the heat of anger. - There were indications of provocation on the part of Agbayani, which mitigated the gravity of the alleged defamatory remarks.

Procedural Issues Involving the Katarungang Pambarangay (Barangay) Conciliation Requirement

• The DOJ noted that the case involved residents and employees of the same city, Las PiAas City, where the incident occurred at the workplace.
• The complaint did not comply with the mandatory referral to the barangay conciliation process as provided under Sections 408 and 409 of Republic Act No. 7160 (Local Government Code of 1991).
• The failure to avail of the required amicable settlement procedure became one of the grounds for dismissing the proceedings under the DOJ ruling.

Allegations of Procedural Irregularities and Extrinsic Fraud

• Agbayani contended that:

- The records at the DOJ were manipulated by suppressing her comment and subsequently attaching 36 additional documents that were not originally filed.

Court of Appeals (CA) Proceedings

• Agbayani sought certiorari before the CA alleging grave abuse of discretion by the DOJ when it reversed the City Prosecutor’s resolution.
• On March 27, 2008, the CA dismissed the petition for certiorari, finding no grave abuse of discretion.
• The CA further affirmed that the discretionary review and determination by the DOJ were within its purview.
• A subsequent motion for reconsideration by Agbayani was denied in a CA Resolution dated July 3, 2008.

Issue:

• Whether the DOJ, by directing the withdrawal of the Information, unreasonably downgraded the charge from grave oral defamation to slight oral defamation.

• Whether the suppression of Agbayani’s comment and the alleged surreptitious attachment of additional documents in the case file constituted extrinsic fraud and grave procedural irregularity.

• Whether respondent Genabe’s petition for review should have been dismissed outright for failing to comply with Sections 5 and 6 of DOJ Circular No. 70, including the requirements of listing the petitioner’s name and address and attaching required documentary evidence.

• Whether Agbayani’s complaint was fatally defective due to non-compliance with the mandatory barangay conciliation process under the Local Government Code of 1991.

• Whether the CA erred in holding that no grave abuse of discretion was committed by the DOJ when it reversed the City Prosecutor’s resolution, given the various allegations raised by Agbayani.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)