G.R. No. 240137 - Department of Fice-Revenue Integrity Protection Service vs. Office of the Ombudsman

The case involves a petition for certiorari filed by the Department of Finance-Revenue Integrity Protection Service (DOF-RIPS) challenging the actions of the Office of the Ombudsman.
The petition addresses the dismissal of complaints against respondent Miriam R. Casayuran in several instances by the Ombudsman through a Joint Resolution (September 30, 2016) and a Joint Order (February 28, 2017).

Violation of Section 7 of Republic Act (R.A.) 3019 (Anti-Graft and Corrupt Practices Act) and Section 8 of R.A. 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees) for failing to file Statements of Assets, Liabilities, and Net Worth (SALNs) for certain calendar years.
Violation of Articles 171 and 183 of the Revised Penal Code (RPC) for making false and untruthful statements in her SALNs.

Allegations of Grave Misconduct and Serious Dishonesty for failing to secure necessary travel authority and for other discrepancies in her official declarations.

Alleged violation of Section 2 of R.A. 1379, contending that Casayuran acquired property manifestly out of proportion to her lawful income during her incumbency.

Purchased a Pasay condominium unit (1996) with specified payment terms and financing schemes.
Acquired a house and lot in Bulacan (1998) with a 25-year installment plan.
Made additional vehicle purchases: a Toyota Revo (circa 2003), a Nissan Sentra (2007), and a Nissan X-Trail (2010), with each involving downpayments, loans, promissory notes, and chattel mortgages.
The properties and vehicles became the basis for alleging that her acquisitions were disproportionate to her official salary and other lawful income.

Casayuran failed to file her SALNs for calendar years 1995, 1997, and 1998.
She also did not declare certain properties (e.g., the Bulacan property and the Sentra) in subsequent SALNs, which formed the factual basis for the charges.

DOF-RIPS relied on Casayuran’s service records, certificates of compensation, her SALNs for various years, and other documentary evidence such as contracts, promissory notes, and mortgage agreements.
The presentation of evidence included a detailed comparison of her monthly salary over the years against her monthly amortization obligations for the properties and vehicles purchased.

The Ombudsman dismissed the criminal and administrative complaints on grounds that either the action had prescribed or that the evidence was insufficient to establish probable cause.
Specifically, the Ombudsman ruled that:

For the SALN non-filing, the complaint had prescribed, as it was filed well beyond the prescribed eight-year period.
For the properties, the evidence failed to prove actual ownership or payment of the installments (e.g., cancellation of the Deed of Conditional Sale for the Bulacan property, absence of proof for the payment of amortizations for the Revo, Sentra, and X-Trail).
The administrative charge regarding failure to secure travel authority was dismissed because of the lapse in time from the occurrence of the misconduct.

The DOF-RIPS filed a Motion for Reconsideration which was denied by the Ombudsman.
The petition before the Court focuses primarily on the criminal and forfeiture charges, asserting that the dismissal under R.A. 6713 and related statutes was erroneous, particularly with regard to the forfeiture charge under R.A. 1379.

Whether the Ombudsman erred in dismissing the criminal charges against Casayuran for:

Violation of Section 7 of R.A. 3019 and Section 8 of R.A. 6713 concerning the non-filing of SALNs for the years 1995, 1997, and 1998.
Violation of Articles 171 and 183 of the RPC regarding the making of false statements in her SALNs.

Whether the Ombudsman erred in dismissing the forfeiture charge under Section 2 of R.A. 1379, particularly in light of allegations that Casayuran’s acquisitions were manifestly out of proportion to her lawful income.

Whether the application of the discovery rule or the prescription period should commence from the commission of the offense or from its discovery, particularly in relation to the non-filing of SALNs.