Case Digest (G.R. No. 173277)
Facts:
- The case involves the Office of the Ombudsman as the petitioner and Engr. Prudencio C. Quimbo as the respondent.
- An administrative complaint was filed by Gilda D. Daradal against Quimbo, alleging sexual harassment and oppression.
- The complaint was lodged on July 19, 1996, claiming Quimbo requested inappropriate massages and made lewd comments.
- After Daradal refused his advances, Quimbo issued a memorandum that effectively removed her from the payroll.
- The Ombudsman-Visayas investigated and dismissed the sexual harassment charge but found Quimbo guilty of oppression, imposing a six-month suspension without pay.
- Quimbo sought reconsideration, which was denied, and then appealed to the Court of Appeals (CA).
- On January 21, 2005, the CA reversed the Ombudsman’s decision, stating the Ombudsman lacked authority to impose direct sanctions.
- The Ombudsman filed a motion for intervention and reconsideration, which the CA denied on May 2, 2006, prompting the Ombudsman to file a petition for certiorari under Rule 65 of the Rules of Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court granted the petition of the Office of the Ombudsman.
- It ruled that the Ombudsman has the power to directly impose administrative penalties against public officials or employees.
- The Court hel...(Unlock)
Ratio:
- The Supreme Court clarified that the Ombudsman is authorized to impose administrative penalties, including suspension, on public officials and employees.
- This power is not merely recommendatory, as previously suggested by the Court of Appeals.
- The Court referenced the 1987 Constitution and Republic Act No. 6770, which outline the Ombudsman’s powers and responsibilities. ...continue reading
Case Digest (G.R. No. 173277)
Facts:
The case involves the Office of the Ombudsman as the petitioner and Engr. Prudencio C. Quimbo as the respondent. The events leading to this case began with an administrative complaint filed by Gilda D. Daradal, a clerk in the Provincial Engineering Office of Catbalogan, Samar, against Quimbo, the Provincial Engineer of Samar. The complaint, lodged on July 19, 1996, alleged sexual harassment and oppression. Daradal claimed that Quimbo requested her to massage his forehead and nape, during which he made inappropriate comments in front of her co-employees. Following her refusal to submit to his advances, Quimbo issued a memorandum detailing her to the Civil Service Commission, effectively removing her from the payroll for a period.
The Ombudsman-Visayas investigated the complaint and, on December 9, 1998, dismissed the sexual harassment charge but found Quimbo guilty of oppression, imposing a six-month suspension without pay. Quimbo sought reconsideration, which was denied. He subsequently appealed to the Court of Appeals (CA), which, on January 21, 2005, reversed the Ombudsman’s decision, stating that the Ombudsman lacked the authority to impose direct sanctions on public officials. The CA ruled that the Ombudsman could only recommend penalties, leaving the actual imposition to the appropriate disciplining authority. The Ombudsman then fi...