Facts:

The case, G.R. NO. 136433, involves Antonio B. Baltazar (petitioner) against several respondents, including the Honorable Ombudsman and various officials of the Department of Agrarian Reform (DAR) in Pampanga: Eulogio M. Mariano, Jose D. Jimenez, Jr., Toribio E. Ilao, Jr., and Ernesto R. Salenga. The events unfolded around a fishpond owned by Paciencia Regala, who leased the property to Eduardo Lapid. Lapid later sub-leased the fishpond to Rafael Lopez while retaining Ernesto Salenga as a watchman. Disputes arose concerning Salenga's payments and rights over the fishpond, prompting Salenga to file a complaint against Lopez and Lapid before the Provincial Agrarian Reform Adjudication Board (PARAB).

On November 24, 1994, Baltazar, who claimed to be a nephew of the fishpond's attorney-in-fact, filed a complaint against the respondents before the Office of the Ombudsman. The complaint alleged conspiracy and violation of RA 3019 (Anti-Graft and Corrupt Practices Act), focusi

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Facts:

Background of the Dispute

• The case involves petitioner Antonio B. Baltazar challenging actions taken by public respondents including the Ombudsman and various officials (Eulogio M. Mariano, Jose D. Jimenez, Jr., Toribio E. Ilao, Jr., and Ernesto R. Salenga).
• The legal controversy arose from a petition for review on certiorari under Rule 45 (Section 27 of RA 6770), seeking to reverse the November 26, 1997 Order and the October 30, 1998 Memorandum issued by the Office of the Special Prosecutor (OSP).

The Underlying Agrarian and Criminal Dispute

• The factual matrix centers on a fishpond dispute in Sasmuan, Pampanga where:
• Paciencia Regala owned a seven-hectare fishpond;
• Her Attorney-in-Fact, Faustino R. Mercado, leased the fishpond for PhP 230,000.00 to Eduardo Lapid for three years (from August 7, 1990, to August 7, 1993).
• Sub-leasing and Employment
• Eduardo Lapid sub-leased the fishpond to Rafael Lopez for seven months (January 10, 1993, to August 7, 1993) at PhP 50,000.00.
• Ernesto R. Salenga was hired by Lapid as a fishpond watchman (bante-encargado) and was reengaged by Lopez under the sublease arrangements.

Emergence of the Administrative and Agrarian Proceedings

• Prior to the current petition, respondent Salenga filed a Complaint before the Provincial Agrarian Reform Adjudication Board (DARAB) in DARAB Case No. 552-P'93 for issues such as unpaid salaries and non-payment of his harvest share.
• Procedural Developments in the Agrarian Case
• Salenga issued a demand for payment via a demand letter and subsequently escalated his grievance by filing the Complaint; he sought relief including a temporary restraining order (TRO) and preliminary injunction.
• Only Salenga appeared at the relevant hearings, resulting in the issuance of a TRO by respondent Toribio E. Ilao, Jr.
• Despite appearances by only one party, the proceedings continued, with interventions by Paciencia Regala (through her Attorney-in-Fact, Faustino Mercado) as her interest in the property was at stake.
• Procedural Steps in the Ombudsman’s Investigation
• On November 24, 1994, petitioner Baltazar (alleged nephew of Faustino Mercado) filed a Complaint-Affidavit before the Ombudsman under docket OMB-1-94-3425, alleging conspiracy and questioning the legitimacy of the TRO that allowed Salenga to take possession and operate the fishpond.
• The Ombudsman, in a series of orders and resolutions, initially found probable cause based on previous resolutions (May 10, 1996 Resolution and October 3, 1996 Order) and recommended the filing of an Information for violation of Section 3 (e) of RA 3019.
• After subsequent motions and re-investigations—including a re-investigation ordered by the Sandiganbayan (August 29, 1997 Order)—the earlier favorable determinations for filing charges were reversed, leading to the dismissal of the criminal complaint.

Petitioner's Allegations and Legal Contentions

• Petitioner alleged that the Ombudsman erred in allowing a Counter-Affidavit (filed by respondent Ilao, Jr.) after the preliminary investigation had been terminated and after an Information had already been filed with the Sandiganbayan.
• Petitioner further contended that respondent Ilao, Jr. reversed his own resolution regarding jurisdictional issues, asserting that the agrarian complaint lacked proper standing because Salenga was merely a “watchman‐overseer” and not an agricultural tenant.
• A preliminary issue was also raised regarding the legal standing (locus standi) of petitioner Baltazar, challenging whether he was the real party in interest and thus entitled to institute the petition.

Issue:

Petitioner's Locus Standi

• Whether petitioner Antonio B. Baltazar, despite being the complainant before the Ombudsman, is a real party in interest with sufficient legal standing to pursue this petition.
• Whether his alleged agency relationship (through a Special Power of Attorney purportedly granted by Faustino Mercado) properly confers him the right to act on behalf of the owner’s interest in the underlying agrarian dispute.

Abuse of Discretion Regarding Procedural Posturing

• Whether respondent Ombudsman (or, by extension, the OSP) committed grave abuse of discretion by permitting the filing of a Counter-Affidavit by respondent Ilao, Jr. after the preliminary investigation had concluded and an Information was already filed before the Sandiganbayan.
• Whether the subsequent orders and the re-investigation, which allowed respondent Ilao, Jr. to submit additional evidence ex parte, were legal and within the wide discretion granted to the courts and administrative bodies.

Jurisdiction Over the Agrarian Dispute

• Whether DARAB had proper jurisdiction over the dispute given the allegations in respondent Salenga’s complaint, which described him as an “agricultural tenant” despite his role as a watchman/encargado.
• Whether the nature of the complaint and the rights asserted therein correctly justified the issuance of a TRO by respondent Ilao, Jr. and subsequent proceedings.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)