Case Digest (G.R. No. 189161)
Facts:
- Judge Adoracion G. Angeles filed a criminal complaint against Senior State Prosecutor Emmanuel Y. Velasco on February 20, 2007.
- The complaint alleged misconduct by Velasco, including:
- Failing to present a key witness in a smuggling case, allegedly benefiting the accused.
- Improperly reopening child abuse cases against Angeles.
- Falsifying a public document to indicate a non-existent clarificatory hearing.
- The Ombudsman issued a Joint Order on March 21, 2007, exonerating Velasco from all charges.
- The Ombudsman found no basis for a preliminary investigation, stating Angeles lacked sufficient personal interest in the smuggling case and that Velasco acted within his prosecutorial discretion.
- Angeles' motion for reconsideration was denied, leading her to file a petition for certiorari under Rule 65 of the 1997 Rules of Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court dismissed Judge Adoracion G. Angeles' petition for certiorari, upholding the Ombudsman's Joint Ord...(Unlock)
Ratio:
- The Court highlighted the principle of non-interference in the Ombudsman’s investigatory and prosecutorial powers, which are constitutionally protected.
- Certiorari is an extraordinary remedy intended to correct jurisdictional errors, not errors of judgment.
- The Ombudsman’s dismissal was based on a thorough evaluation of evidence and a lack of sufficient grounds for a preliminary investigation.
- The Court found no grave abuse of discretion, as Angeles did not prove that the Ombudsman acted arbitrarily or capriciously.
- The Court supported the Ombudsman’s findings that Velasco’s actions were within his discretion and t...continue reading
Case Digest (G.R. No. 189161)
Facts:
The case involves Judge Adoracion G. Angeles as the petitioner and several officials from the Office of the Ombudsman, including Senior State Prosecutor Emmanuel Y. Velasco, as respondents. The events leading to this case began on February 20, 2007, when Judge Angeles, then the Presiding Judge of Branch 121 of the Caloocan City Regional Trial Court, filed a criminal complaint against Velasco with the Ombudsman. The complaint alleged that Velasco, in his capacity as a prosecutor, committed several acts of misconduct: (1) failing to present a material witness in a smuggling case, which allegedly gave unwarranted advantage to the accused; (2) improperly insisting on reopening child abuse cases against Angeles; and (3) falsifying a public document to suggest that a clarificatory hearing had taken place when it had not. The Ombudsman evaluated the complaint and issued a Joint Order on March 21, 2007, exonerating Velasco from all charges. The Ombudsman found no cause for a preliminary investigation or administrative adjudication, stating that Angeles lacked sufficient personal interest in the smuggling case and that Velasco acted within his discretion as a prosecutor. Angeles ...