Facts:

The case involves Hilario P. Soriano as the petitioner and the Ombudsman, represented by Simeon V. Marcelo, along with Hon. Jennifer A. Agustin-Se, Graft Investigation Officer I, Wilfred L. Pascasio, Graft Investigation Officer II, and Leoncia R. Dimagiba, the respondents. The events leading to this case began on July 1, 2002, when Soriano filed a criminal and administrative complaint against Dimagiba, who was then the 2nd Assistant City Prosecutor of Manila City. Soriano accused Dimagiba of violating Section 3(e) of Republic Act No. 3019, also known as the Anti-Graft and Corrupt Practices Act. He alleged that Dimagiba exhibited manifest partiality by recommending the reopening of a preliminary investigation into a case against Mely Palad, who was the subject of a complaint for falsification of public documents filed by Soriano.

Soriano claimed that Dimagiba had previously approved a resolution and information against Palad but later recommended reopening the case six mont...

Facts:

1. Filing of Complaint: On July 1, 2002, Hilario P. Soriano (petitioner) filed a criminal and administrative complaint with the Office of the Ombudsman against Leoncia R. Dimagiba (Dimagiba), a 2nd Assistant City Prosecutor of Manila. The complaint alleged that Dimagiba violated Section 3(e) of Republic Act (R.A.) No. 3019 (Anti-Graft and Corrupt Practices Act) by showing manifest partiality and giving unwarranted benefits to Mely Palad, against whom Soriano had filed a complaint for falsification of public documents.

2. Allegations Against Dimagiba: Soriano claimed that Dimagiba, after initially recommending the filing of a case against Palad, later recommended the reopening of the preliminary investigation six months later, citing "the interest of justice" without providing specific reasons. Soriano argued that this action was arbitrary and showed partiality.

3. Dimagiba’s Defense: In her Counter-Affidavit, Dimagiba denied the allegations, stating that her recommendation to reopen the case was based on procedural grounds. She explained that Palad had filed a Motion to Reopen the case, and the absence of proof that Palad received the subpoena during the preliminary investigation was a substantial deficiency that needed correction to avoid further delays.

4. Ombudsman’s Resolution: The Ombudsman, through Graft Investigation Officer Jennifer A. Agustin-Se, dismissed Soriano’s complaint, finding no evidence of manifest partiality or bad faith on Dimagiba’s part. The Ombudsman noted that Dimagiba’s recommendation was based on procedural concerns and was approved by the City Prosecutor, following office policy.

5. Motion for Reconsideration: Soriano filed a Motion for Reconsideration, which was denied by the Ombudsman for lack of merit and for being filed out of time.

Issue:

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Ruling:

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Ratio:

1. Certiorari Limited to Errors of Jurisdiction: The Court reiterated that certiorari is a remedy to correct errors of jurisdiction, not errors of judgment. The Ombudsman’s findings, supported by substantial evidence, are beyond the scope of certiorari.

2. Ombudsman’s Discretion: The Court emphasized the independence of the Ombudsman in exercising its investigatory and prosecutorial powers. The Ombudsman’s decision to dismiss the complaint, based on the lack of evidence to establish probable cause, was within its discretion and not tainted by grave abuse of discretion.

3. Elements of Violation of R.A. No. 3019, Section 3(e): The Court outlined the elements required to establish a violation of Section 3(e) of R.A. No. 3019, which include: (1) the accused must be a public officer; (2) the accused must have acted with manifest partiality, evident bad faith, or inexcusable negligence; and (3) the action must have caused undue injury or given unwarranted benefits to any party. The Court found that Soriano failed to prove these elements against Dimagiba.

4. Presumption of Good Faith: The Court upheld the presumption of good faith in favor of public officers. Soriano failed to rebut this presumption, as there was no evidence that Dimagiba acted with self-interest, ill will, or ulterior motives in recommending the reopening of the case.

5. Purpose of Preliminary Investigation: The Court reiterated that the purpose of a preliminary investigation is to protect the innocent from hasty and oppressive prosecution. The Ombudsman’s decision to dismiss the complaint was consistent with this purpose, as there was insufficient evidence to sustain a prima facie case against Dimagiba.

Conclusion:

The Supreme Court dismissed the petition, affirming the Ombudsman’s dismissal of Soriano’s complaint against Dimagiba. The Court found no grave abuse of discretion in the Ombudsman’s decision and upheld the presumption of good faith in favor of public officers.