Case Digest (G.R. No. 229811)
Facts:
- The case involves the Office of the Ombudsman, represented by Conchita Carpio Morales, as the petitioner against Oscar Gonzales Malapitan, the respondent.
- A criminal complaint was filed on February 16, 2015, against several public officials, including Malapitan, for violations of the Anti-Graft and Corrupt Practices Act (Republic Act No. 3019).
- The complaint was based on the alleged misuse of Malapitan's Priority Development Assistance Fund (PDAF) amounting to P8,000,000.00, approved for the Kalookan Assistance Council, Inc. in 2009, during his term as Caloocan City First District Representative.
- Malapitan was initially excluded from the administrative complaint, which charged other officials with grave misconduct and gross neglect of duty.
- On January 22, 2016, the Ombudsman sought to amend the complaint to include Malapitan, claiming he was inadvertently omitted.
- The Task Force PDAF approved this amendment on February 22, 2016.
- Malapitan filed a motion for reconsideration, which was denied, leading him to seek relief from the Court of Appeals via a Petition for Certiorari and Prohibition.
- On August 31, 2016, the Court of Appeals ruled in favor of Malapitan, nullifying the Ombudsman’s orders to include him in the complaint, citing the condonation doctrine.
- The Ombudsman’s motion for reconsideration was dismissed on January 31, 2017, prompting the current petition for review on certiorari.
Issue:
- (Unlock)
Ruling:
- The Supreme Court denied the petition, affirming the Court of Appeals' decision.
- The Court held that the condonation doctrine applied to Malapitan since the alleged misconduct occurred in 2009, and he was reelected in 2010.
- The Court ruled that the Court of Appeal...(Unlock)
Ratio:
- The Supreme Court clarified that the abandonment of the condonation doctrine took effect on April 12, 2016, after the finality of the Carpio Morales case.
- Since the administrative complaint against Malapitan was filed in January 2016 and admitted in February 2016, the condonation doctrine was still applicable.
- The doctrine allows for the exculpation of public officials from administrative liability if they are reelected after ...continue reading
Case Digest (G.R. No. 229811)
Facts:
The case involves the Office of the Ombudsman, represented by Conchita Carpio Morales, as the petitioner against Oscar Gonzales Malapitan, the respondent. The events leading to this case began when the Office of the Ombudsman’s Public Assistance and Corruption Prevention Office filed a criminal complaint on February 16, 2015, against several public officials, including Malapitan, for violations of the Anti-Graft and Corrupt Practices Act (Republic Act No. 3019). The complaint stemmed from the alleged anomalous use of Malapitan's Priority Development Assistance Fund (PDAF) amounting to P8,000,000.00, which was approved to fund programs of the Kalookan Assistance Council, Inc. in 2009, while Malapitan was serving as the Caloocan City First District Representative.
Malapitan was not initially included in the administrative complaint, which charged other officials with grave misconduct, gross neglect of duty, and conduct prejudicial to the best interest of service. On January 22, 2016, the Ombudsman filed a motion to amend the complaint to include Malapitan, claiming he had been inadvertently left out. The Task Force PDAF granted this motion on February 22, 2016. Malapitan subsequently filed a motion for reconsideration, which was denied, prompting him to seek relief from the Court of Appeals through a Petition for Certiorari and Prohibition.
On August 31, 2016, the Court of Appeals ruled in favor of Malapitan, nullifying the Ombudsman’s orders to implead him in the administrative complaint. The Court of Appeals reasoned that the condonation doctrine applied to Malapitan’s case, as he had been reelected in 2010 after the alleged misconduct in 2009, thus implyi...