Case Digest (G.R. No. 133077)
Facts:
The case involves Adoracion G. Angeles as the petitioner against several respondents, including Hon. Aniano A. Desierto, the Ombudsman of the Philippines, and various officials from the Department of Social Welfare and Development (DSWD) and the Department of Justice (DOJ). The events leading to this case began with a criminal complaint filed against Angeles by her housemaids, Proclyn Pacay and Nancy Gaspar, for physical abuse and maltreatment under Republic Act No. 7610. This complaint was assigned to Senior State Prosecutor Hernani T. Barrios. In response to the ongoing investigation, Angeles filed a motion to dismiss the complaint, which was initially granted. However, subsequent developments led to the filing of another complaint against her by a former helper, Rebecca Pacay, which was consolidated with the earlier case.
On July 25, 1996, a Joint Resolution was issued recommending the dismissal of the complaint against Rebecca Pacay while recommending the filing of cha...
Case Digest (G.R. No. 133077)
Facts:
Background of the Case
- Petitioner Adoracion G. Angeles filed a special civil action for certiorari and mandamus under Rule 65 of the Rules of Court, seeking the annulment of several issuances by the Office of the Ombudsman in connection with OMB-0-97-0047.
- The case stemmed from a criminal complaint filed against the petitioner by her housemaids, Proclyn Pacay and Nancy Gaspar, for physical abuse and maltreatment under Republic Act (R.A.) No. 7610 (Special Protection of Children Against Child Abuse, Exploitation, and Discrimination Act).
Initial Proceedings
- The complaint, docketed as I.S. No. 95-224, was assigned to Senior State Prosecutor (SSP) Hernani T. Barrios for investigation.
- On April 21, 1995, the petitioner filed a motion to submit the case for resolution and requested its dismissal.
- On June 21, 1995, SSP Barrios issued a subpoena for the petitioner to appear and present evidence. During the hearing on July 18, 1995, the petitioner reiterated her plea to submit the case for resolution, which was granted.
Administrative Complaint Against SSP Barrios
- On January 12, 1996, the petitioner filed an administrative complaint against SSP Barrios for dishonesty, gross negligence, and incompetence due to the delay in resolving I.S. No. 95-224.
- On January 15, 1996, the petitioner filed an urgent motion to disqualify SSP Barrios from handling the case.
Consolidation of Cases
- Another criminal complaint, I.S. No. 96-258, was filed against the petitioner and her sister by Rebecca Pacay, a former helper. This case was later re-docketed as I.S. No. 96-097 and consolidated with I.S. No. 95-224.
- The consolidated cases were assigned to State Prosecutors Richard Anthony D. Fadullon and Alfredo P. Agcaoili.
Joint Resolution and Denial of Motion for Reconsideration
- On July 25, 1996, SPs Fadullon and Agcaoili issued a Joint Resolution recommending the dismissal of Rebecca Pacay's complaint and the filing of two informations against the petitioner for violation of Section 10(a) of R.A. No. 7610.
- The petitioner filed a motion for partial reconsideration, which was denied by Acting Chief State Prosecutor Pascualita Duran-Cereno on October 7, 1996.
- The petitioner's petition for review with the Department of Justice (DOJ) was also denied on January 16, 1997.
Complaint Filed with the Ombudsman
- Dissatisfied, the petitioner filed an Affidavit-Complaint with the Office of the Ombudsman (OMB-0-97-0047) against DSWD Secretary Lina B. Laigo, Assistant Chief State Prosecutor Pascualita Duran-Cereno, SSP Hernani T. Barrios, and SPs Richard Anthony D. Fadullon and Alfredo P. Agcaoili.
- The petitioner accused the respondents of violating Article 171(5) of the Revised Penal Code (falsification), Section 3(f) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act), and R.A. No. 7610 (child abuse).
Ombudsman's Resolution and Denial of Motion for Reconsideration
- On September 18, 1997, Graft Investigation Officer II Roline M. Ginez-Jabalde recommended the dismissal of OMB-0-97-0047.
- On November 20, 1997, Special Prosecution Officer III Carlos D. Montemayor recommended the approval of the September 18, 1997 Resolution.
- On January 23, 1998, the Ombudsman denied the petitioner's motion for reconsideration.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Discretion of the Ombudsman: The Ombudsman has broad investigatory and prosecutorial powers under the Constitution and R.A. No. 6770. Courts should not interfere with the Ombudsman's exercise of discretion unless there is clear abuse.
- Conspiracy and Bad Faith: Conspiracy requires evidence of actual cooperation, not mere allegations of intimacy or bias. The petitioner failed to provide sufficient evidence to prove conspiracy or bad faith among the respondents.
- Falsification: The allegation that respondents Barrios, Fadullon, and Agcaoili falsified a document by ante-dating a resolution was unfounded. The unsigned resolution had no legal effect and could not be used as evidence of falsification.
- Violations of R.A. No. 3019 and R.A. No. 7610: The petitioner's claims of undue interest and child abuse were not substantiated. The respondents' actions were within their official duties and did not constitute violations of the cited laws.
Conclusion:
- The Supreme Court upheld the Ombudsman's dismissal of the petitioner's complaint, finding no grave abuse of discretion. The petition was dismissed for lack of merit.