G.R. No. 164679 - Office of the Ombudsman vs. Andutan, Jr.

Procedural Background
The Office of the Ombudsman filed a petition for certiorari before the Supreme Court to overturn the Court of Appeals’ (CA) July 28, 2004 decision (CA-G.R. SP No. 68893), which annulled the Ombudsman’s July 30, 2001 finding of gross neglect of duty against Uldarico P. Andutan, Jr.
The CA held that (a) Section 20(5) of R.A. 6770 prohibited investigations filed more than one year after the act complained of, and (b) Andutan’s resignation divested the Ombudsman of jurisdiction.

Underlying Charges and Administrative Proceedings
Uldarico P. Andutan, Jr. was Deputy Director of the DOF One-Stop Shop Tax Credit and Duty Drawback Center. Pursuant to an Executive Secretary memorandum, he resigned effective July 1, 1998.
On September 1, 1999, the Fact Finding and Intelligence Bureau (FFIB) of the Ombudsman criminally charged Andutan and others with estafa via falsification of public documents and RA 3019 violations, and administratively charged Andutan with grave misconduct, dishonesty, falsification of official documents, and conduct prejudicial to the service, in connection with illegal transfer of Tax Credit Certificates worth ₱242,433,534 to Steel Asia.
On July 30, 2001, the Ombudsman found Andutan guilty of gross neglect of duty, imposing forfeiture of benefits, perpetual disqualification from public office, and related penalties.
After denial of reconsideration, Andutan appealed to the CA, which set aside the Ombudsman’s decision on the grounds of prescription under Section 20(5) and lack of jurisdiction post-resignation.

Does Section 20(5) of R.A. 6770 bar the Ombudsman from investigating complaints filed more than one year after the act complained of?
Does Andutan’s resignation before the administrative complaint was filed render the case moot for lack of jurisdiction?
If the administrative case is not moot, are the Ombudsman’s findings supported by substantial evidence?