Case Digest (G.R. No. 170815)
Facts:
Office of the Ombudsman v. Priscilla Lazaro-Baldazo, G.R. No. 170815, February 02, 2007, Supreme Court First Division, Garcia, J., writing for the Court.The petition arose from an administrative complaint filed with the Office of the Ombudsman on October 15, 1999 by Ricardo Gonzaga against Priscilla Lazaro-Baldazo, then Municipal Civil Registrar of Bustos, Bulacan. Ricardo alleged that Baldazo falsified a Deed of Donation dated September 18, 1995 by making it appear that his wife, Teofista Lazaro-Gonzaga, executed the deed when Teofista was allegedly incapable of doing so; he also accused Baldazo of falsifying Teofista's Death Certificate by portraying Bustos, Bulacan as the place of death when Ricardo contended Teofista actually died at the Philippine General Hospital in Manila.
Baldazo filed a counter-affidavit dated December 28, 1999 denying the charges. She asserted the deed, initially undated, was immediately taken and retained by Ricardo and his sister after execution in August 1995; she denied manipulating the date. She further claimed that the Death Certificate was prepared by Ricardo and his sister with the assistance of her staff and denied causing any falsification. During a preliminary conference before the Ombudsman the parties agreed to submit the case for resolution on their position papers.
On June 21, 2000 the Ombudsman found Baldazo administratively liable for Dishonesty and recommended her dismissal; her motion for reconsideration was denied. Baldazo elevated the case to the Court of Appeals (docketed CA-G.R. SP No. 61502). In its decision dated April 27, 2005 the Court of Appeals reversed and set aside the Ombudsman's decision, finding the evidence insufficient to prove falsification of public documents. The Court of Appeals denied Ricardo's motion for reconsideration on December 7, 2005.
The Ombudsman filed a petition for review on certiorari under Rule 45 of the Rules of Court before the Supreme Court, assig...(Pro-only)
Issues:
- Whether the petition raises a question of law reviewable under Rule 45 or merely questions of fact not subject to Supreme Court review.
- Whether the evidence established falsification of the Deed of Donation and/or the Death Certificate such that Baldazo was administratively guilty of Dishonesty...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)