G.R. No. 234260 - Linsangan vs. Office of the Ombudsman

Petition for Review on Certiorari under Rule 45 filed by petitioner Atty. Teodoro C. Linsangan seeking to reverse and set aside decisions rendered by the Office of the Ombudsman and the Court of Appeals.
The case arose from a controversy involving the verification of land titles wherein a certification was issued by petitioner, then-Registrar of Deeds, concerning the non-existence of certain certificates of title.

On July 31, 2008, Leonardo O. Orig and his sister-in-law, Lourdes P. Francisco, visited the Registry of Deeds in Cabanatuan City to verify the existence of three Original Certificates of Title (OCT Nos. 19327, 19062, and 16947) and one Transfer Certificate of Title (TCT No. 13764).
Their request initially yielded no positive results despite repeated inquiries, prompting a subsequent visit during which petitioner, along with Vault Keeper Emilio De Guzman and Officer-in-Charge Marlon B. Romero, issued a certification indicating that the mentioned titles could not be located despite diligent efforts.
It later emerged that the titles were recorded as severely mutilated and no longer recognizable according to an inventory dating back to 1982.

Unconvinced by the Registry’s explanation, Orig personally attempted to verify the existences of the certificates by checking the list of lost and missing titles maintained by Romero.
Discrepancies arose when Romero allegedly inserted title numbers into the list, leading Orig to attach machine copies of OCT Nos. 19062 and 19327 in his reply and claim that the certification was false.
Orig asserted that the issuance of the certification amounted to gross negligence on the part of petitioner.

Petitioner contended that he only assumed the office on October 1, 1986 and was not involved when the lost titles inventory was originally prepared.
He later admitted that the certification contained an erroneous fact, attributing the error to the actions of his subordinates, De Guzman and Romero.
Additionally, petitioner noted that by the time of further communications, he had already been dismissed on grounds of grave misconduct (from another case) and had subsequently retired from service.

The Office of the Ombudsman, in its January 9, 2015 Decision, found petitioner guilty of gross neglect of duty for failing to perform the requisite level of verification expected of his office and imposed the penalty of dismissal—later converted into a fine with additional accessory penalties.
The Court of Appeals (CA) in its Decision dated April 7, 2017, affirmed the Ombudsman’s ruling as it maintained that petitioner could not rely solely on the signatures of his subordinates to absolve himself of his responsibility.
Petitioner’s subsequent Motion for Reconsideration with the CA was denied in a Resolution dated August 17, 2017.

Whether there was gross negligence on the part of petitioner in the issuance of the certification.
Whether the penalty imposed upon petitioner was excessively harsh in relation to the infraction committed.
Whether the complaint against petitioner should be dismissed on the ground that Leonardo O. Orig, as the complainant, lacked personal interest in the matter.
Whether petitioner’s constitutional right to a speedy disposition of his case was violated considering the length of the administrative and investigative proceedings.