Case Digest (G.R. No. 174902-06)
Facts:
Alfredo R. Enriquez, Gener C. Endona, and Rhandolfo B. Amansec v. Office of the Ombudsman, G.R. Nos. 174902-06, February 15, 2008, Supreme Court First Division, Sandoval‑Gutierrez, J., writing for the Court.
On May 9, 2000, the Fact‑Finding and Intelligence Bureau (FFIB) of the Office of the Ombudsman filed five separate Complaints‑Affidavits with the Administrative Adjudication Bureau of the Ombudsman charging, among others, petitioners Alfredo R. Enriquez (Administrator, Land Registration Authority), Gener C. Endona (LRA Legal Officer and PBAC member), and Rhandolfo B. Amansec (Chief, LRA Inspection and Investigation Division) with administrative and criminal offenses arising from the bidding of the Land Titling Computerization Project. The complaints were docketed as OMB‑ADM‑0‑00‑0415, OMB‑ADM‑0‑00‑0416, OMB‑ADM‑0‑00‑0417 (administrative) and OMB‑0‑00‑0873, OMB‑0‑00‑0874 (criminal).
Respondent required the petitioners to submit counter‑affidavits; petitioners filed a Joint Counter‑Affidavit denying the charges. The Ombudsman thereafter conducted hearings. On June 15, 2001, FFIB filed its Formal Offer of Evidence; petitioners filed comments on July 10, 2001. Petitioners formally offered their evidence on January 29, 2002; FFIB filed its comment on April 17, 2002. After the formal offers, petitioners awaited resolution but received none.
Petitioners took procedural steps to prompt action: a Motion to Set Date for Simultaneous Filing of Memoranda (July 12, 2002) and repeated personal follow‑ups; co‑respondent Edilberto R. Feliciano filed a Motion for Early Resolution (December 12, 2002). No disposition followed. On March 24, 2006, petitioners moved to dismiss the cases for inordinate delay, asserting denial of their constitutional right to a speedy disposition and alleging reputational harm, anxiety, and loss of employment and retirement opportunities; FFIB did not object, yet the cases remained unresolved.
On October 20, 2006, petitioners filed a petition under Rule 65 of the 1997 Rules of Civil Procedure seeking a writ of mandamus directing the Ombudsman to dismiss the administrative and criminal complaints for its alleged grave abuse of discretion in failing to resolve the cases. Respondent, through the Solicitor General, opposed, arguing (inter alia) that mandamus wa...(Subscriber-Only)
Issues:
- Is a petition for a writ of mandamus under Rule 65 an appropriate remedy to compel the Office of the Ombudsman to resolve the administrative and criminal complaints against petitioners?
- Did the Office of the Ombudsman violate petitioners' constitutional right to a speedy dispo...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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