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. H...

Facts:

1. Administrative Complaint:
Gilda D. Daradal, a clerk in the Provincial Engineering Office of Catbalogan, Samar, filed an administrative complaint against Engr. Prudencio C. Quimbo, the Provincial Engineer of Samar, for Sexual Harassment and Oppression. The complaint was filed with the Office of the Ombudsman-Visayas (Ombudsman-Visayas) and docketed as OMB-VIS-ADM-96-04846.

2. Allegations of Sexual Harassment:
Daradal alleged that on July 19, 1996, Quimbo asked her to massage his forehead and nape. During this, he made inappropriate remarks, including, "You had been lying to me you have already seen my manhood. When shall I have to see yours?" This was allegedly done in the presence of her co-employees.

3. Allegations of Oppression:
Daradal further claimed that Quimbo ordered her detail to the Civil Service Commission in Catbalogan, Samar, through a Memorandum dated August 6, 1996. Her name was removed from the payroll of the Provincial Engineering Office from August 16-31, 1996, allegedly due to her refusal to submit to his sexual advances.

4. Quimbo’s Defense:
Quimbo denied the allegations, stating that Daradal enjoyed "VIP treatment" and rebelled when required to work. He argued that the charges were fabricated to embarrass him and that his decision to detail her was valid.

5. Motion for Withdrawal:
On March 26, 1996, Daradal filed a motion to withdraw her complaint, but the Ombudsman-Visayas denied the motion on August 11, 1998.

6. Ombudsman-Visayas Ruling:
On December 9, 1998, the Ombudsman-Visayas dismissed the sexual harassment charge but found Quimbo guilty of Oppression, imposing a six-month suspension without pay. Quimbo’s motion for reconsideration was denied on April 15, 1999.

7. CA Ruling:
Quimbo appealed to the Court of Appeals (CA), which reversed the Ombudsman-Visayas’ decision on January 21, 2005. The CA ruled that the Ombudsman could only recommend penalties, not directly impose them. The Ombudsman filed a motion for intervention and reconsideration, which the CA denied on May 2, 2006.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Ombudsman’s Disciplinary Authority:
   The Ombudsman has the constitutional and statutory authority to directly impose administrative penalties on erring public officials. This power is derived from Section 13(3) of Article XI of the 1987 Constitution and Republic Act No. 6770.

2. Legal Standing to Intervene:
   The Ombudsman has a clear legal interest in defending its decisions, as its role is to ensure accountability and integrity in public service. Denying its intervention would undermine its constitutional mandate.

3. Proper Penalty for Oppression:
   Oppression is classified as a grave offense under Civil Service rules, warranting a penalty of six months and one day to one year of suspension for the first offense. The Court adjusted the penalty to reflect this classification.

Dispositive Portion

The Supreme Court granted the petition, nullified and set aside the CA’s January 21, 2005 Decision and May 2, 2006 Resolution, and reinstated the Ombudsman-Visayas’ December 9, 1998 Resolution and April 15, 1999 Order with the modification that the penalty imposed on Quimbo be six months and one day of suspension without pay.