G.R. No. 119281 - Veterans Federation of the Philippines vs. Court of Appeals

In 2008, Raul V. Gatuz, then Barangay Captain of Barangay Tabang, Plaridel, Bulacan, faced an administrative complaint for Abuse of Authority and Dishonesty filed by Felicitas L. Domingo on February 21, 2008.
The complaint was docketed as Administrative Case No. OMB-L-A-08-0126-C before the Office of the Ombudsman.
On November 17, 2008, the Office of the Deputy Ombudsman for Luzon rendered a decision finding Gatuz guilty of Dishonesty and imposed a penalty of a three-month suspension without pay.

On May 20, 2009, the Deputy Ombudsman for Luzon indorsed its decision to the Secretary of the Interior and Local Government (DILG) for immediate implementation.
The DILG received the indorsement on May 29, 2009 and subsequently received a copy of the decision on June 30, 2009, which set in motion the administrative steps for implementing the suspension.

Raul Gatuz moved for reconsideration of the disciplinary decision on July 7, 2009.
The DILG deferred the implementation of the Ombudsman's decision pending a resolution of the motion for reconsideration.
In line with its inquiry about the effect of recent case law, the DILG referred to the ruling in Office of the Ombudsman v. Samaniego to gauge the scope and impact of such motions.

On October 22, 2009, the DILG issued a memorandum directing its Regional Director for Region III to implement the suspension of Gatuz.
On November 17, 2009, Gatuz filed a Petition for Declaratory Relief and Injunction in the Regional Trial Court (RTC) of Malolos, Bulacan (Civil Case No. 808-M-2009) asking for:

A determination of his rights pending the resolution of his motion for reconsideration.
A temporary restraining order (TRO) to prevent the DILG from executing the suspension.

The Samaniego ruling applied only to appeals rather than motions for reconsideration.
The Samaniego decision had not yet attained finality due to the pending motion for reconsideration.
Memorandum Circular (MC) No. 1, Series of 2006, clearly stated that filing a motion for reconsideration or a petition for review does not stay the implementation of the Ombudsman's decisions unless a TRO or writ of injunction is in force.
The RTC was argued to lack jurisdiction since the action was essentially directed against the decision of the Ombudsman.

The RTC possessed jurisdiction over the action for declaratory relief and injunction.
The filing of a motion for reconsideration, similar to an appeal, should automatically stay the execution of the Ombudsman's decision, referencing precedents such as Samaniego and Lapid v. Court of Appeals.
The case was argued to have become moot since Gatuz had already appealed the Ombudsman decision before the Court of Appeals.

On January 18, 2010, the RTC issued a decision declaring the October 22, 2009, DILG memorandum void and permanently prohibiting its implementation.
The RTC’s ruling was primarily based on the interpretation that a motion for reconsideration serves as a precursor to an appeal and thus merits staying the execution of the disciplinary decision.
Following the RTC decision, on March 26, 2010, the DILG filed the present petition for review on certiorari before the Supreme Court.
Simultaneously, on June 15, 2010, Gatuz filed a Petition for Review before the Court of Appeals regarding the Ombudsman's decision.

Whether the RTC had proper jurisdiction to issue a declaratory relief and injunction restraining the DILG from implementing the Ombudsman's disciplinary decision.

Whether the filing of a motion for reconsideration (or an appeal) automatically stays the execution of the disciplinary decision rendered by the Ombudsman, as argued by the respondent.

Whether the Samaniego decision, in conjunction with MC No. 1, Series of 2006, governs the conduct of implementation by the DILG while a motion for reconsideration is pending.