G.R. No. 80544 - Lee vs. Rodil

On February 3, 1997, Pablo Aloro, a private respondent and retired employee receiving a monthly pension from the Social Security System, lodged a complaint for dishonesty against Jessie Macalalag, the petitioner and an employee of the Philippine Postal Corporation in Bacolod City.
The complaint arose when Aloro discovered that his missing pension checks for April, May, and July 1996 were allegedly taken by Macalalag, who encashed them for his personal benefit.

The Office of the Ombudsman for Visayas received the complaint and initiated administrative proceedings.
Several orders were issued directing the petitioner to file an answer (dated February 18, July 7, and November 13, 1997, and April 24, 1998), but the petitioner failed to file any required response.
During a preliminary conference held on October 27, 1998, the petitioner only sent a telegram requesting a postponement and asking to submit his position paper later; however, he never submitted any such paper.
As a result, the investigating officer had no choice but to resolve the case solely on the evidence presented by the private respondent.

It was established that when Aloro, upon learning about his missing pension checks at the Bacolod City Post Office, confronted Macalalag, the latter issued him a personal check for ₱7,320.00.
The check, however, was dishonored by the drawee bank due to insufficient funds.
Despite executing an affidavit of desistance by Aloro—presumably to seek the dismissal of the case—such affidavit was rejected.
The Ombudsman proceeded to declare petitioner Macalalag administratively liable, ordered his dismissal from service, mandated the forfeiture of all benefits, and imposed a disqualification from government service.

The petitioner sought reconsideration of the adverse decision through a petition for review on certiorari to the Supreme Court.
Citing the decision in Fabian v. Desierto and Administrative Circular No. 99-2-01-SC, the Supreme Court dismissed his petition for review, leaving the Ombudsman's decision final.
Undeterred, the petitioner filed an action for annulment of judgment with the Court of Appeals on the ground that his former counsel's gross negligence deprived him of his day in court.
The Court of Appeals dismissed the petition for lack of jurisdiction, referencing Section 9(2) of B.P. Blg. 129 and the established appellate doctrine limiting its jurisdiction over judgments or orders not rendered by Regional Trial Courts.

Is the Court of Appeals vested with jurisdiction over actions for annulment of decisions or orders of the Ombudsman in administrative cases?
Does the inclusion of quasi-judicial bodies, whose functions or rank are akin to those of Regional Trial Courts, fall under the ambit of Section 47 of the Rules of Court concerning annulment of judgments?

Can the remedy of annulment of judgment be invoked in administrative disciplinary cases involving the Ombudsman, given that such actions traditionally pertain to judgments rendered by Regional Trial Courts?
Shall petitioner be allowed to resort to annulment on the basis of extrinsic fraud or lack of jurisdiction after having pursued other available remedies, including his appeal to the Supreme Court?