Title
Alarilla vs. Lorenzo
Case
G.R. No. 240124
Decision Date
Aug 31, 2022
A former mayor and her husband faced allegations of misappropriating public funds. The Supreme Court dismissed the case due to the OMB's inordinate delay, violating her right to speedy disposition.
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Case Digest (G.R. No. 240124)

Facts:

Background of the Parties
Eduardo Alarilla was the former Mayor of Meycauayan, Bulacan, serving from 1992 to 1995 and re-elected for three consecutive terms ending in 2007. Joan V. Alarilla, the petitioner, is Eduardo’s wife and was elected Mayor of Meycauayan in 2007, serving until 2013. During her term, Eduardo served as the General Consultant of the Meycauayan City government.

Disbursement of Checks
From July to August 2007, the petitioner approved 41 checks drawn from the Municipality of Meycauayan’s account, issued as payment to LC San Pascual Construction Supply and VSP Trading and General Merchandise for goods and services delivered.

Complaint Filed
On January 18, 2008, Rolando L. Lorenzo (respondent) filed a complaint against the petitioner and Eduardo for grave misconduct, dishonesty, and malversation through falsification of public documents. He alleged that the petitioner, in concert with her husband, misappropriated public funds by issuing checks for goods and services not actually delivered.

OMB Proceedings
The Office of the Ombudsman (OMB) required the petitioner and Eduardo to file counter-affidavits, which they did on July 9, 2008. The parties were then directed to file position papers. Eduardo passed away on March 4, 2009, and the OMB dismissed the complaint against him due to lack of jurisdiction.

OMB Decision
On November 2, 2016, the OMB found the petitioner administratively liable for grave misconduct and serious dishonesty and imposed the penalty of dismissal from service with accessory penalties. This decision was approved on December 16, 2016, and the petitioner’s motion for reconsideration was denied on March 1, 2017.

CA Proceedings
The petitioner filed a Petition for Review with the Court of Appeals (CA), which affirmed the OMB’s decision on January 30, 2018. The CA agreed with the petitioner’s administrative liability and rejected her claim of inordinate delay. The petitioner’s motion for reconsideration was also denied.

Petition to the Supreme Court
The petitioner filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, raising issues of inordinate delay and administrative liability.

Issue:

  1. Whether the petitioner’s right to the speedy disposition of her case was violated due to the OMB’s inordinate delay.
  2. Whether the petitioner is administratively liable for grave misconduct and serious dishonesty.

Ruling:

The Supreme Court granted the petition. It ruled that the petitioner’s right to the speedy disposition of her case was violated due to the OMB’s inordinate delay of nearly eight years in resolving the administrative complaint. The Court dismissed the administrative complaint against the petitioner without addressing the issue of her administrative liability.

Ratio:

  1. Right to Speedy Disposition of Cases: The Constitution guarantees the right to a speedy disposition of cases, which extends to administrative proceedings. The OMB failed to resolve the case within a reasonable period, as the proceedings dragged on for nearly eight years without justification. The Court emphasized that the OMB’s inaction violated its mandate to act promptly on complaints.

  2. Inordinate Delay: The Court applied the guidelines set in Cagang v. Sandiganbayan, determining that the OMB’s delay was unreasonable and violated the petitioner’s constitutional rights. The case involved a straightforward administrative complaint, and the evidence was not so voluminous or complex as to justify the delay.

  3. Prohibition of Motions to Dismiss: The Court noted that the OMB’s rules prohibit motions to dismiss in administrative cases, leaving the petitioner no legitimate avenue to assert her right to speedy disposition earlier. The petitioner’s invocation of this right in her motion for reconsideration was deemed timely.

  4. Dismissal of the Case: Given the violation of the petitioner’s right to speedy disposition, the Court dismissed the administrative complaint without addressing the merits of her alleged administrative liability.


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