Case Digest (G.R. No. 176596)
Facts:
The case involves Judge Adoracion G. Angeles, the petitioner, who was formerly the Presiding Judge of the Regional Trial Court (RTC), Branch 121, Caloocan City. The events leading to the case began in June 1999 when Judge Angeles was charged with child abuse by her grandniece, Maria Mercedes Vistan. The preliminary investigation of the complaint was assigned to State Prosecutor Emmanuel Y. Velasco of the Department of Justice (DOJ). On June 20, 1999, Velasco filed a case against Angeles for 21 counts of Child Abuse under Republic Act No. 7610, known as the Special Protection of Children against Child Abuse, Exploitation and Discrimination Act. Following this, Angeles filed a petition for review with the DOJ Secretary, who, in a resolution dated April 4, 2000, ordered the withdrawal of the Information against her.
Subsequently, on July 7, 2000, Angeles filed an administrative complaint against Velasco for Gross Misconduct, Gross Ignorance of the Law, Incompetence, and Manife...
Case Digest (G.R. No. 176596)
Facts:
Background of the Case
- Petitioner Adoracion G. Angeles, a former Presiding Judge of the Regional Trial Court (RTC), Branch 121, Caloocan City, was charged with 21 counts of child abuse by her grandniece, Maria Mercedes Vistan, in June 1999.
- The preliminary investigation was conducted by State Prosecutor Emmanuel Y. Velasco (respondent Velasco) of the Department of Justice (DOJ), who recommended filing the case against petitioner under Republic Act (RA) No. 7610 (Special Protection of Children against Child Abuse, Exploitation and Discrimination Act).
- The DOJ Secretary, upon review, ordered the withdrawal of the Information against petitioner on April 4, 2000.
Administrative Complaint Against Velasco
- On July 7, 2000, petitioner filed an administrative complaint against respondent Velasco for Gross Misconduct, Gross Ignorance of the Law, Incompetence, and Manifest Bad Faith. The DOJ dismissed the complaint, and petitioner's motion for reconsideration was denied on February 18, 2002.
- Petitioner then filed a Petition for Review with the Office of the President (OP), challenging the DOJ's dismissal of her administrative complaint.
Libel Complaint Against Velasco
- In his Comment to the OP, respondent Velasco made statements questioning petitioner's character, including allegations about her personal life and relationships. Petitioner claimed these statements were defamatory and filed a libel complaint against Velasco.
- The Office of the City Prosecutor of Manila dismissed the libel complaint, finding the statements privileged and not defamatory. Petitioner's motion for reconsideration was also denied.
DOJ and OP Proceedings
- Petitioner filed a Petition for Review with the DOJ Secretary, which was dismissed on March 17, 2004. Her motion for reconsideration was denied on June 25, 2004.
- Petitioner then filed a Petition for Review with the OP, which was dismissed on July 29, 2004, citing Memorandum Circular (MC) No. 58, which prohibits appeals to the OP in cases not involving offenses punishable by reclusion perpetua to death.
Court of Appeals Decision
- Petitioner filed a petition for review with the Court of Appeals (CA), which denied the petition on August 30, 2006. The CA upheld the OP's reliance on MC No. 58 and ruled that the DOJ resolutions had become final and executory.
Issue:
- Whether the Court of Appeals erred in applying the doctrine of qualified political agency.
- Whether the validity of Memorandum Circular No. 58 can be collaterally attacked.
- Whether the DOJ resolutions became final and executory when petitioner failed to elevate them directly to the Court of Appeals within 60 days.
- Whether the Office of the President erred in not taking cognizance of the petition due to Memorandum Circular No. 58.
- Whether the DOJ erred in not finding probable cause for libel against respondent Velasco.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court upheld the dismissal of petitioner's libel complaint and affirmed the finality of the DOJ resolutions. The Court emphasized the importance of finality in judicial and administrative decisions and the validity of the President's delegation of authority under the doctrine of qualified political agency.