Case Summary (G.R. No. 133347)

Motion for Reconsideration Overview

The petitioners, Eugenio Lopez Jr., Oscar Lopez, Augusto Almeda-Lopez, and ABS-CBN Broadcasting Corporation, filed a Motion for Reconsideration against the Supreme Court's Decision in G.R. No. 133347. The initial ruling dismissed their petition for certiorari due to the absence of grave abuse of discretion by the Ombudsman, who found no probable cause to indict the respondents for various criminal offenses under the Revised Penal Code (RPC). The key points of the initial Decision included:

• Dismissal of respondents Roberto S. Benedicto and Salvador (Buddy) Tan due to their deaths.
• Affirmation that the Ombudsman did not exhibit grave abuse of discretion in dismissing the criminal complaint.

Petitioners' Arguments for Reconsideration

The petitioners presented two main arguments in their Motion for Reconsideration:

1. The execution and validity of the letter-agreement dated June 8, 1973, are irrelevant to determining the criminal liability of the respondents.
2. The deaths of respondents Benedicto and Tan should not result in their dismissal as respondents in the case.

• Petitioners also filed a Motion to Refer the Case to the Court en banc, asserting that their arguments present novel legal questions.
• They contended that the ratification of the letter-agreement does not affect the determination of criminal liability and that the continuation of criminal complaints against deceased respondents is permissible.

Court's Response to Petitioners' Arguments

The Court found no merit in the petitioners' arguments, stating that:

• The issues raised do not constitute novel questions of law warranting en banc consideration.

• There is no ongoing criminal case against the deceased respondents, and thus, they should be dropped from the case.

• The Court emphasized that the determination of grave abuse of discretion is a settled procedural issue and does not present a novel legal question.

Analysis of the Ombudsman's Dismissal

The Court reiterated that the Ombudsman’s dismissal of the criminal complaints was justified due to the lack of probable cause. The petitioners' complaint-affidavits were deemed insufficient to establish a well-founded belief that crimes had been committed. The specific allegations included:

• Meetings between Senator Estanislao Fernandez and Senator Taada regarding rental agreements.

• Claims of illegal takeovers and unauthorized withdrawals from ABS-CBN facilities.

• The Court concluded that the Ombudsman did not commit grave abuse of discretion in dismissing the complaints.

Clarification on Ratification and Criminal Liability

The Court clarified that it did not state that ratification extinguishes criminal liability. Instead, it applied the concept of ratification to assess the conflicting claims regarding the letter-agreement. The elements required to establish a violation of Article 298 of the RPC were not met, particularly the absence of intent to defraud, as the petitioners later sought to enforce the terms of the letter-agreement.

• The petitioners' actions indicated an affirmation of the letter-agreement, undermining their claims of coercion.

Implications of Filing Claims Against the Estate

The Court noted that the petitioners had filed a claim against the estate of Benedicto based on the letter-agreement, which precluded them from asse...continue reading

Case Syllabus (G.R. No. 133347)

Case Background

• Petitioners: ABS-CBN Broadcasting Corporation and its officers, Eugenio Lopez, Jr., Augusto Almeda-Lopez, and Oscar M. Lopez.
• Respondents: Office of the Ombudsman, Roberto S. Benedicto, Exequiel B. Garcia, Miguel V. Gonzales, and Salvador (Buddy) Tan.
• Jurisdiction: The Supreme Court of the Philippines.
• Date of Resolution: April 23, 2010.
• Case Reference: G.R. No. 133347.

Nature of the Case

• The case revolves around a Motion for Reconsideration filed by the petitioners seeking to overturn a prior decision that dismissed their petition for certiorari against the Ombudsman.
• The Ombudsman had previously resolved that there was no probable cause to indict the respondents for multiple alleged violations of the Revised Penal Code (RPC), including:
  • Article 298: Execution of Deeds by Means of Violence or Intimidation
  • Article 315: Estafa
  • Article 308: Theft
  • Article 302: Robbery
  • Article 312: Usurpation of Real Rights in Property
  • Article 318: Other Deceits.

Key Issues Raised in Motion for Reconsideration

• Petitioners contended two main arguments:
  • The execution and validity of the letter-agreement dated June 8, 1973, were irrelevant to determining the criminal liability of the respondents.
  • The dismissal of respondents Benedicto and Tan due to their deaths was inappropriate.

...continue reading