G.R. No. 83768 - Radio Communications of the Philippines, Inc. vs. Rodriguez

On March 22, 2008, between 10:00 p.m. and 11:00 p.m., a Barangay Tanod from Brgy. Solis, Municipality of Balete, Batangas, reported to the Balete Police Station the discovery of a dead person lying on the street of Brgy. Solis.
SPO2 Melencio Landicho, SPO1 Jayson Alvares Paran, and three other policemen proceeded to the alleged crime scene for verification.
At the scene in Brgy. Solis, the police found the lifeless body of Damiano M. Manguiat near the store of Brgy. Captain Vicente Bathan.
Later, the police also recovered the cadaver of Victorio M. Manguiat, the older brother of Damiano, from a forested area.

On April 4, 2008, Erlinda B. Manguiat, widow of Damiano, filed an amended Complaint-Affidavit accusing Brgy. Captain Bathan and six other persons for the killing of Damiano and Victorio.
In her complaint, Erlinda alleged that she had instructed her sons, Lary and Dennis Manguiat, to retrieve their father and uncle from the house of a person named "Lando."
Upon return, Lary and Dennis claimed that they witnessed Brgy. Captain Bathan, together with barangay tanods and private persons, assaulting and shooting the victims.
The complaint was supported by the affidavits of Lary and Dennis, detailing the events of that night.

On May 30, 2008, SPO1 Paran executed an affidavit stating that at dawn on March 23, 2008, he and SPO2 Landicho went to Lary’s house to inform him of his father’s death.
SPO1 Paran claimed that upon informing Lary, the latter reacted with the phrase “siningil agad si itay?” indicating disbelief or shock.
In response to SPO1 Paran’s account, on June 11, 2008, both Erlinda and Lary filed affidavits contesting his version of events.
Notably, Lary stated that he never had any conversation with SPO1 Paran, asserting that SPO2 Landicho was the sole officer who had visited him around 2:00 a.m. on March 23, 2008.

On July 9, 2008, Erlinda filed an administrative complaint with the Ombudsman charging SPO1 Paran with Dishonesty, Grave Misconduct, Conduct Prejudicial to the Best Interest of the Service, and Oppression, as well as a criminal complaint for Perjury.
In Decision OMB-L-A-08-0432-G dated March 16, 2011, the Ombudsman found SPO1 Paran guilty of Simple Dishonesty, resulting in his suspension from office for one month and one day without pay.
SPO1 Paran’s motion for reconsideration was denied in the subsequent Resolution dated October 4, 2011.
In Resolution OMB-L-C-08-0520-G, also dated March 16, 2011, the Ombudsman ruled that there was probable cause to believe that SPO1 Paran committed the crime of Perjury and recommended the filing of an information with the appropriate court.

Whether the Ombudsman gravely abused its discretion by finding SPO1 Paran guilty of Dishonesty and ordering his suspension for one month and one day without pay.
Whether the Ombudsman seriously erred and gravely abused its discretion in ruling that there is probable cause to believe that SPO1 Paran committed the crime of Perjury.