Case Summary (G.R. No. 143419)
Background of the Case
The case arose from a letter-complaint filed by five employees of the NIA against petitioner del Rosario, alleging violations of the Anti-Graft and Corrupt Practices Act and related laws. The initial administrative complaint was docketed as OMB-ADM-0-91-0341, while the criminal aspect was registered as OMB-0-91-1540. Following an investigation, the Ombudsman dismissed the criminal case but later allowed a supplemental motion for reconsideration, resulting in the filing of two informations against petitioner: Criminal Case No. 22715 for estafa through falsification of public documents and Criminal Case No. 22716 for violation of RA 3019.
Procedural History and Pre-trial Developments
Petitioner contested the informations, alleging they violated the provisions of the Ombudsman Act of 1989 and related administrative orders. A motion to withdraw the charges was dismissed, and while one case was eventually withdrawn due to insufficient evidence, the Sandiganbayan denied petitioner's motion to quash the remaining information in Criminal Case No. 22715. A request for certiorari was later dismissed by the Supreme Court due to petitioner's non-compliance with procedural requirements.
The Pre-trial Order and Its Implications
The Sandiganbayan conducted a pre-trial conference, during which a pre-trial order was issued on May 2, 2000. Petitioner challenged this order, asserting that he was unjustly denied the opportunity to mark documents for his defense and raise the question of the validity of the information against him. The crux of his argument centered on whether the Supreme Court's prior dismissal of his petition constituted res judicata, barring him from addressing these issues in the ongoing criminal proceedings.
Judicial Decision and Rationale
The Court dismissed the petition, stating that it was procedurally flawed as it sought to challenge an interlocutory order, which cannot be addressed through a petition for review on certiorari under Rule 45. Even if the appeal were permitted, the petition would still fail because the issues raised were already settled in the previous case, and thus, res judicata applied. The Court held that the dismissal of petitioner's prior action was a decision on th
...continue readingCase Syllabus (G.R. No. 143419)
Case Overview
- Case Citation: 525 Phil. 261
- Date of Decision: June 22, 2006
- Petitioner: Jose B. del Rosario, Jr.
- Respondents: The People of the Philippines and the Office of the Special Prosecutor
- Context: Petition for review on certiorari regarding a pre-trial order from the Sandiganbayan in Criminal Case No. 22715.
Background of the Case
- On July 19, 1991, five employees of the National Irrigation Administration (NIA), led by Atty. Musa I. Malayang, filed a letter-complaint against Jose B. del Rosario, Jr., who was then the Administrator of NIA.
- The complaint alleged violations of the Anti-Graft and Corrupt Practices Act (Republic Act No. 6713), the Revised Penal Code, and various rules from the Commission on Audit and the Civil Service Commission.
- The complaint was split into administrative (OMB-ADM-0-91-0341) and criminal (OMB-0-91-1540) aspects.
- The Office of the Ombudsman dismissed the criminal case on June 15, 1992, with a subsequent dismissal on September 30, 1992, and denial of motions for reconsideration on December 10, 1993.
Development of the Case
- A supplemental motion for reconsideration was granted on March 7, 1995, leading to the filing of two informations against the petitioner:
- Criminal Case No. 22715 for estafa through falsification of public documents.
- Criminal Case No. 22716 for violation of RA 3019, Section 3 (e).
- On May 23, 1995, petitioner filed a motion to withdraw the info