A.C. No. 11550 - Trovela vs. Robles

Manuel B. Trovela (complainant) filed a disbarment complaint against Pasig City Assistant Prosecutor Michael B. Robles for issuing a resolution dated September 29, 2011, recommending dismissal of Trovela’s estafa complaint for insufficiency of evidence.
Complaint likewise sought disbarment of Prosecutor II Emmanuel L. ObuAgen and City Prosecutor Jacinto G. Ang for approving the dismissal recommendation.
Former Prosecutor General Claro A. Arellano and former DOJ Secretary Leila M. De Lima were also named for alleged inordinate delay in resolving Trovela’s petition for review and motion for reconsideration.

On May 25, 2011, Trovela charged Katigbak, Salonga, and Reyes with estafa under Article 315(1)(b) of the Revised Penal Code for failure to remit deductions from Trovela’s pay to the Meralco Employees Savings and Loan Association (MESALA) despite payroll deductions.
Trovela was terminated from Sky Cable effective July 6, 2006, yet payroll deductions continued until mid-August 2006. Upon account closure in September 2006, Trovela found the deductions were not remitted to MESALA.
In a resolution dated September 29, 2011, Robles recommended dismissal of the estafa complaint for insufficiency of evidence, later approved by ObuAgen and Ang on October 11, 2011.

Trovela filed a petition for review on November 3, 2011, which Arellano affirmed in a February 12, 2013 resolution upholding dismissal.
Trovela’s motion for reconsideration was denied by De Lima on April 21, 2015.
Trovela then filed disbarment proceedings asserting:

Alleged misapplication of law and disregard of jurisprudence requiring no demand to prove estafa.
Sustained erroneous presumptions in review and reconsideration decisions by Arellano and De Lima.
Inordinate delays in resolving petitions suggest lack of diligence and dereliction of duty.
Instances of alleged corruption, manipulative schemes by Sky Cable, and unjust judgments were ignored by DOJ officials.
Procedural and substantive lapses indicated gross violation of laws and Canons of Legal Profession by respondents.

Whether the Integrated Bar of the Philippines (IBP) has jurisdiction to investigate and discipline government lawyers charged with administrative offenses arising from their official duties.
Whether respondents committed acts warranting disbarment or administrative disciplinary actions based on the allegations of mishandling, undue delay, and violations of laws in the estafa complaint proceedings.