G.R. No. 257685 - Commission on Human Rights vs. Office of the Ombudsman

The Commission on Human Rights (CHR) filed a complaint before the Office of the Ombudsman against Police Superintendent Robert C. Domingo, PO2 Dylan Verdan, PO2 Jonathan Ubarre, PO1 Berly Apolonio, and other John Does.
Allegations included violations under the Revised Penal Code (arbitrary detention, delay in delivery of detainees, grave threats, grave coercion, robbery/extortion), Republic Act No. 9745 (Anti-Torture Act), and the 2013 Revised Philippine National Police Operational Procedures.

The CHR visited Raxabago Police Station 1 (Tondo, Manila), discovering a "secret detention cell" inside the Drug Enforcement Unit (DEU) office.
The cell was described as cramped (1m x 5m), dark, fetid, with no lighting or windows, having only one male urinal.
Twelve detainees (3 women, 9 men) were found inside, allegedly arrested for drug offenses.
Detainees' names were not listed in station logbooks; they allegedly were unlawfully arrested and deprived of food and inquest proceedings.
Some detainees claimed physical abuse (beatings, electrocution with tasers) and extortion (payments demanded for release).

PSUPT Domingo claimed detainees were lawfully arrested during an anti-criminality operation on April 27, 2017.
The "secret detention cell" was described as a "holding room" used for separation, security, and decongestion.
The holding room reportedly had sufficient lighting, ventilation, water, and urinals.
On April 27, 2017, the station held 78 men and 18 women detainees despite a capacity of 50.
Allegations of torture, unlawful arrest, and extortion were denied; some respondents did not submit counter-affidavits.

The Office of the Ombudsman dismissed the criminal and administrative complaints (July 28, 2020) for lack of probable cause.
It ruled CHR failed to prove detention beyond allowed period and that allegations of abuse were unsupported by credible evidence.
The Ombudsman noted sworn statements by detainees largely contradicted CHR's claims; medical exams showed no injury.
The holding room’s conditions were recognized as cramped but deemed a result of jail congestion and budget constraints.
CHR’s motion for reconsideration was denied (May 18, 2021).

CHR filed a Petition for Certiorari alleging grave abuse of discretion by the Ombudsman for applying a "clear and convincing evidence" standard instead of "probable cause".
Respondents submitted comments and counter-affidavits; Ombudsman declined to comment further.

Whether the Ombudsman gravely abused its discretion in dismissing the criminal complaint against the respondents for lack of probable cause.
Whether the Ombudsman applied an incorrect quantum of evidence standard by requiring clear and convincing evidence instead of probable cause in dismissal of the complaint.