Title
Office of the Ombudsman vs. Quimbo
Case
G.R. No. 173277
Decision Date
Feb 25, 2015
The Supreme Court affirms the Ombudsman's authority to impose administrative penalties, reinstating a six-month suspension without pay for Prudencio C. Quimbo due to sexual harassment and oppression.
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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

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