G.R. No. 169108 - Intercontinental Broadcasting Corp. vs. Alonzo Legasto

On January 29, 2001, an Information for violation of Section 3(e) of Republic Act No. 3019 was filed against Dominador C. Ferrer, Jr., then Administrator of the Intramuros Administration (IA), alleging the unlawful award of lease contracts.
The Information charged that during or around August 20, 1998, petitioner, while executing his official duties in Manila, acted with manifest partiality, bad faith, and gross negligence by giving unwarranted benefits to Offshore Construction and Development Company.
Allegations included the improper award of lease contracts for areas within Intramuros without conducting the mandatory public bidding as required by joint circulars and permitting the construction of structures without the necessary permits, thereby harming the public interest.

An administrative complaint was simultaneously initiated against petitioner, leading to proceedings with the Office of the Ombudsman and later with the Presidential Commission Against Graft and Corruption (PCAGC).
On February 29, 2000, the Office of the President reviewed the administrative case and absolved petitioner of administrative liability, concluding that he acted in good faith and within the scope of his authority.
Despite this administrative clearance, the criminal case was already pending before the Sandiganbayan.

A Motion for Reinvestigation (filed on April 4, 2001) which was denied on evidentiary grounds, as the Court held that factual contentions were for a full trial.
A Motion for Reconsideration shortly after, followed by a Supplemental Motion for Reconsideration alleging forum shopping by the complainants due to the prior dismissal of the administrative case.

A second motion for reconsideration was also pursued through a Motion for Leave to File, which was similarly denied on the ground that administrative and criminal cases are independent and one does not bar the other.
On May 19, 2003, petitioner filed a Motion for Re-determination of Probable Cause, invoking the Office of the President ruling that had cleared him administratively.
The Sandiganbayan subsequently issued a Resolution on July 2, 2003, denying the Motion for Re-determination of Probable Cause, citing that the issues had already been resolved in prior motions and by the decisions of both the Court and the Supreme Court.
Petitioner then filed another Motion for Reconsideration and/or to Quash the Information on August 4, 2003, arguing that his administrative clearance should automatically dismiss the criminal case. This motion was denied by the Sandiganbayan on October 22, 2003.

Petition for Certiorari and Judicial Debate Over Administrative Versus Criminal Liability

Petitioner elevated the case by filing a Petition for Certiorari with the Supreme Court, alleging grave abuse of discretion and arguing that the dismissal of the administrative case should bar the criminal prosecution for the same acts.
Petitioner maintained that since he had been cleared administratively, the criminal proceeding should likewise be terminated.
Both the public and private prosecutors countered by asserting that issues that had been resolved in the administrative case do not preclude independent criminal liability and that the administrative dismissal does not have res judicata effect over the criminal proceedings.
Prior relevant decisions, such as Paredes, Jr. v. Sandiganbayan and Tan v. Comelec, were cited to emphasize that administrative and criminal proceedings are separate and distinct.

The sequence of motions and resolutions, including the dismissal of earlier petitions (such as the certiorari petition in G.R. No. 153592, which was dismissed on procedural grounds) illustrate petitioner’s repeated attempts to delay or quash the criminal process.
The final posture before the Supreme Court was that the Sandiganbayan’s Resolutions—denying the re-determination of probable cause and the subsequent Motion for Reconsideration—had acquired finality.
The petition was viewed as an abuse of legal process intended to delay the arraignment and trial of the criminal case.

Whether the finding of lack of administrative liability (i.e., the dismissal of the administrative case) automatically bars the filing and continuation of a criminal case for the same or similar acts.

Does petitioner’s administrative clearance (by the Office of the President) serve as a valid basis to quash the pending criminal case before the Sandiganbayan?
Should the principle of res judicata or finality in administrative cases be extended to criminal prosecutions, thereby dismissing criminal liability for actions already cleared administratively?
Are the issues of administrative and criminal liability intrinsically related or sufficiently separate such that a decision in one does not bind the other?

The propriety of petitioner’s repeated filing of motions and the alleged forum shopping as a delaying tactic.

Whether petitioner's tactic of filing multiple motions, including appeals to previous decisions, contradicts the independent nature of the two proceedings.
If the issue of forum shopping was appropriately addressed by the Sandiganbayan in recognizing the distinct nature of the administrative and criminal actions.