G.R. No. 194157 - Araullo vs. Office of the Ombudsman

Romeo R. Araullo, previously employed by Club Filipino as an electrician and later as Maintenance Supervisor, was dismissed on December 23, 2000.
Araullo filed a labor complaint for illegal dismissal against Club Filipino, which initially was dismissed by Labor Arbiter Fedriel Panganiban but later overturned on appeal by the Court of Appeals and the Supreme Court, ordering his reinstatement and payment of full backwages and benefits.

Following the final favorable labor judgment, Araullo moved for the issuance of a writ of execution with Labor Arbiter Panganiban – later reassigned to LA Arden S. Anni due to a re-raffle caused by Panganiban’s inhibition on further hearing the matter.
LA Anni approved Araullo’s motion, issuing a writ of execution directing the sheriff to collect the amount computed at P2,338,152.25.

Club Filipino filed a Motion to Recompute the judgment award, challenging the writ on the ground that the computation was premature and unresolved.
Before hearing the motion to recompute, LA Anni issued an Order on August 12, 2008 quashing the writ and lifting the notice of garnishment served upon Metrobank and the Bank of the Philippine Islands.
LA Anni later inhibited himself from further involvement, given his fraternity relationship with Club Filipino’s President, Atty. Roberto F. De Leon, and its counsel, Atty. Ernesto P. Tabao.

Dissatisfied with the quashing of the writ, Araullo filed a petition to set aside LA Anni’s order, which was denied via a Resolution dated October 29, 2008 by the NLRC First Division, composed of NLRC Chairman Gerardo C. Nograles, Commissioner Romeo L. Go, and Commissioner Perlita B. Velasco.
The NLRC further endorsed the case records to the arbitration branch of origin to resolve pending issues affecting the final computation of the award and the issuance of a writ of execution.

Feeling aggrieved by the delays and procedural irregularities, Araullo filed a criminal complaint (docketed as OMB-C-C-09-0410-H) before the Office of the Ombudsman against respondents including LA Anni, NLRC Commissioners (Nograles, Go, Velasco), and private lawyers Atty. De Leon, Atty. Tabao, and Atty. Filomemo B. Balbin.
The complaint charged the respondents with violations of Article 206 of the Revised Penal Code (RPC) for issuing unjust interlocutory orders and Section 3(e) of Republic Act No. 3019 (the Anti-Graft and Corrupt Practices Act) for purportedly giving undue advantage to Club Filipino through manifest partiality, inexcusable negligence, and bad faith.
Specific allegations included:

LA Anni’s issuance of an interlocutory order quashing the writ without affording due process to Araullo by failing to serve his counsel with Club Filipino’s motion.
A conspiracy between LA Anni and the club’s legal representatives to delay the enforcement of Araullo’s favorable judgment.
The conduct of the NLRC Commissioners in endorsing the order, which purportedly showed undue advantage towards Club Filipino and caused Araullo undue injury and stress.

The Office of the Ombudsman, through a resolution issued by Graft Investigation and Prosecution Officer I Romualdo V. Francisco and approved by then Ombudsman Ma. Merceditas N. Gutierrez, dismissed Araullo’s criminal charges.
The resolution held that the deferral in executing the judgment was attributable to the proper application of the NLRC Rules of Procedure and that the respondents had acted within the scope of their official duties.
It was emphasized that the presumption that public officials correctly perform their duties was not rebutted by sufficient evidence to support the allegations of grave abuse of discretion.

Araullo subsequently filed a petition for certiorari to assail the Ombudsman’s resolution dismissing his criminal complaint.
The central contention in the petition was that the dismissal was tainted by grave abuse of discretion in overlooking manifest partiality, inexcusable negligence, and the arbitrary issuance of an interlocutory order by the respondents.

The Supreme Court ultimately dismissed Araullo’s petition for certiorari, reiterating its policy of non-interference with the determinations and procedural rulings of the Office of the Ombudsman, except in clear cases of grave abuse of discretion.

Whether the Office of the Ombudsman committed grave abuse of discretion in dismissing Araullo’s criminal complaint for alleged violations of Article 206 of the RPC and Section 3(e) of R.A. No. 3019.
Whether there existed probable cause, based on the facts and allegations presented, to support the criminal charges against the respondents, including LA Anni and the NLRC Commissioners.
Whether the procedural actions taken by LA Anni (e.g., issuance and subsequent quashing of the writ of execution) and the NLRC officials (affirming LA Anni’s order) exhibited manifest partiality, evident bad faith, or gross inexcusable negligence, thereby justifying criminal prosecution.
Whether the dismissal of the criminal complaint was proper considering the application of relevant procedural rules and the established requirement for proving a criminal offense beyond mere procedural irregularities.