Case Digest (G.R. No. 171188)
Facts:
- The case involves the People of the Philippines as the petitioner against Jessie B. Castillo, the Municipal Mayor of Bacoor, and Felicito R. Mejia, the Municipal Building Official.
- In September 1999, Mejia issued Notices of Violation to stallholders leasing property from complainant Cesar Sarino for operating without necessary building permits.
- After repeated non-compliance, Mejia's office warned stallholders of impending closure.
- On January 24, 2000, a task force closed the stalls by erecting galvanized iron fences.
- Lessees Pepito B. Aquino and Adriano G. Samoy filed a complaint against Castillo, Mejia, and two other officials for violations of the Anti-Graft and Corrupt Practices Act.
- The Office of the Ombudsman dismissed this complaint on October 20, 2000, citing good faith in the officials' actions.
- On September 6, 2001, Sarino filed a new complaint against Castillo and Mejia for criminal violations and administrative misconduct due to the fence installation.
- The Ombudsman dismissed Sarino's administrative complaint on March 10, 2003, as moot due to Castillo's re-election.
- On May 7, 2003, the Ombudsman filed an Information against the respondents for violation of Section 3(e) of the Anti-Graft and Corrupt Practices Act.
- The Sandiganbayan initially found probable cause but later dismissed the case on October 10, 2005, ruling it was a rehash of the earlier complaint.
- The Office of the Special Prosecutor's motion for reconsideration was denied on January 18, 2006, leading to the current petition for review.
Issue:
- (Unlock)
Ruling:
- The Supreme Court granted the petition, reversing the Sandiganbayan's resolutions dated October 10, 2005, and January 18, 2006.
- The Information against the respondents was reinstated....(Unlock)
Ratio:
- The Supreme Court highlighted the difference between executive and judicial determinations of probable cause.
- The executive determination by the Ombudsman involves broad discretion to assess grounds for filing charges, while the judicial determination is limited to evidence for issuing ...continue reading
Case Digest (G.R. No. 171188)
Facts:
The case involves the People of the Philippines as the petitioner against respondents Jessie B. Castillo, the Municipal Mayor of Bacoor, and Felicito R. Mejia, the Municipal Building Official. The events leading to this case began in September 1999 when Mejia issued Notices of Violation to stallholders leasing property owned by complainant Cesar Sarino, located in front of SM Bacoor, Cavite, for operating without the necessary building permits. Following repeated non-compliance, Mejia's office sent letters to the stallholders, warning them of impending closure. On January 24, 2000, a task force from the Bacoor Municipal Hall closed the stalls by erecting galvanized iron fences.
In response, lessees Pepito B. Aquino and Adriano G. Samoy filed a complaint against Castillo, Mejia, and two other municipal officials for violations of the Anti-Graft and Corrupt Practices Act. The Office of the Ombudsman dismissed this complaint on October 20, 2000, citing good faith in the actions taken by the local officials. Subsequently, on September 6, 2001, Sarino filed a new complaint against Castillo and Mejia, alleging criminal violations of the same act and administrative misconduct due to the installation of the fence, which he claimed unlawfully deprived him of the use of his property.
The Ombudsman dismissed Sarino's administrative complaint on March 10, 2003, as moot due to Castillo's re-election and the timing of the complaint. However, on May 7, 2003, the Office of the Ombudsman filed an Information against the respondents for violation of Section 3(e) of the Anti-Graft and Corrupt Practices Act, leading to the Sandiganbayan's issuance of arrest warrants. After a reinvestigation and subs...