Case Digest (G.R. No. 256513)
Case Digest (G.R. No. 256513)
Facts:
Johnifer Galamay Batara, Fe Divina Gracia Laysa, Senen Carlos Bacani, and Rodolfo Corpus Undan v. Office of the Ombudsman, G.R. No. 256513, May 19, 2025, the Supreme Court Second Division, Lopez, M., J., writing for the Court.The petitioners (Batara, et al.) are former members of the PhilRice Board of Trustees; the respondent is the Office of the Ombudsman (Ombudsman). The administrative complaints originated from separate FIO complaints dated June 15, 2011, accusing the petitioners, fellow trustees, the then Executive Director Ronilo Beronio, and cashier Fe N. Lumawag of participating in the approval and implementation of a PhilRice Car Plan (the Car Plan) that allegedly misused public funds and avoided required public procurement. The Board of Trustees (BOT) initially approved, in principle, piloting a Car Plan by Resolution No. 208-08-52 on November 5, 2008, describing a rental scheme subject to an administrative order and modifications; subsequent BOT minutes show differing discussions (renting from dealers vs. beneficiaries acquiring vehicles).
In January 2009 PhilRice's Executive Director issued Administrative Order Nos. 2009-02 and 2009-05 (and an addendum AO No. 2009-05A) prescribing guidelines that enabled beneficiaries to obtain bank loans (PNB) and for PhilRice to enter Hold-Out Agreements and lease contracts with beneficiaries; PhilRice paid beneficiaries PHP 2,860,787.60 from February to August 2009. On May 14, 2009 the executive director issued AO No. 2009-15 on private vehicle rentals; the BOT on June 19, 2009 revisited and confirmed rental guidelines while noting problems with the Car Plan.
On September 1, 2016 the Ombudsman issued a Joint Decision (OMB-C-A-13-0182, OMB-L-A-13-0336, OMB-L-A-13-0358) finding numerous respondents including Batara, et al. guilty of grave misconduct for allowing Hold-Out Agreements and car-rental disbursements without public bidding and for causing undue injury to PhilRice; it meted dismissal and accessory penalties. The respondents' motions for reconsideration at the Ombudsman were denied.
Batara, et al. appealed to the Court of Appeals in CA-G.R. SP Nos. 152169, 152214, and 152282. The CA, in a Decision dated February 7, 2020 (Fifth Division), affirmed the Ombudsman and found grave misconduct; later Resolutions (including one dated September 3, 2020) dismissed Batara, et al.’s Motion for Reconsideration as filed out of time and ordered entry of judgment; a February 19, 2021 CA Resolution denied other respondents’ motions for reconsideration. Batara, et al.’s counsel claims he did not receive the February 7, 2020 Decision until June 17, 2020 (after a change of address filed February 4, 2019), and thus filed a Motion for Reconsideration on July 1, 2020 which the CA deemed late.
Batara, et al. filed a Petition for Review on Certiorari under Rule 45 to the Supreme Court, contesting (a) violation of their right to speedy disposition of cases, (b) the timeliness of their CA Motion for Reconsideration and the CA’s entry of judgment, and (c) liability for grave misconduct. The Supreme Court took the case and resolved the issues below.
Issues:
- Was Batara, et al.’s right to speedy disposition of cases violated?
- Did Batara, et al. timely move for reconsideration of the CA’s February 7, 2020 Decision, such that the Entry of Judgment must be set aside?
- Are Batara, et al. liable for grave misconduct?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)