Case Summary (G.R. No. 240137)
Applicable Law
The legal context includes Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act), Republic Act No. 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees), and Article 171 and Article 183 of the Revised Penal Code regarding falsification of public documents and perjury. The ruling also concerns Section 2 of R.A. 1379, relating to the forfeiture of unlawfully acquired properties by public officials.
Background Facts
Miriam R. Casayuran was appointed as Clerk II on February 13, 1990. Throughout her tenure, she acquired several properties and vehicles, including a condominium unit, a house and lot in Bulacan, and multiple cars, leading to the issuance of complaints against her for failing to file her Statement of Assets, Liabilities and Net Worth (SALN) and for alleged unreported income exceeding her lawful earnings.
The Ombudsman’s Initial Ruling
On September 30, 2016, the Ombudsman dismissed the complaints against Casayuran, concluding that there was no probable cause or substantial evidence against her. The Ombudsman indicated that the action for failing to file her SALN had already prescribed and declared that the allegations regarding her properties did not amount to unlawful acquisition, as the DOF-RIPS lacked adequate proof of irregularities.
Rationale for Dismissal of SALN Charges
The prescriptive period for filing complaints under R.A. 6713 is eight years. The Ombudsman stated that since the DOF-RIPS filed its complaint over a decade after the alleged violations for 1995, 1997, and 1998, such actions were barred by prescription. Furthermore, the Ombudsman noted that although Casayuran did not file her SALN, there was insufficient evidence to prove she unlawfully acquired the properties in question.
Findings on Property Acquisition
The Ombudsman examined the evidence related to the properties allegedly acquired by Casayuran and established that her income, coupled with loans and other financial sources, sufficiently explained the purchases. Specifically, Casayuran's salary increased significantly during her tenure, enabling her to make substantial purchases, and the DOF-RIPS failed to present evidence proving she did not meet her financial obligations.
Arguments in the Petition
In its petition, the DOF-RIPS contended that the Ombudsman erred in dismissing the charges. They asserted that the prescriptive period should begin from the discovery of the violations and that Casayuran’s allegations of financial ability did not account for her increased expenditures or the lack of reported properties, particularly the significant increase in her asset values compared to her declared income.
Court’s Rulings on Criminal Charges
The court agreed with the Ombudsman’s dismissal of the charges under R.A. 6713 and R.A. 3019 due to the expiration
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Overview of the Case
- The case arises from a Petition for Certiorari filed by the Department of Finance-Revenue Integrity Protection Service (DOF-RIPS) against the Office of the Ombudsman and Miriam R. Casayuran.
- The petition challenges the Ombudsman’s Joint Resolution dated September 30, 2016, and the Joint Order dated February 28, 2017, which dismissed multiple complaints against Casayuran.
- The complaints included allegations of corruption, misconduct, and failure to file necessary financial disclosures.
Background of Respondent
- Miriam R. Casayuran was appointed as Clerk II in the Bureau of Customs on February 13, 1990, and later promoted to Customs Operations Officer III on January 26, 1998.
- Throughout her career, she made several significant property purchases, including:
- A condominium in Pasay City for P506,100.00 in 1996.
- A house and lot in Bulacan for P271,000.00 in 1998.
- A Toyota Revo in 2003 for P675,000.00.
- A Nissan Sentra in 2007 for P660,000.00.
- A Nissan X-Trail in 2010 for P1,473,544.00.
Allegations Against Casayuran
- The DOF-RIPS filed complaints alleging:
- Criminal Charges:
- Violations of the Anti-Graft and Corrupt Practices Act (R.A. 3019) and the Code of Conduct and Ethical Standards for Public Officials and Employees (R.A. 6713).
- Falsification of documents as per Articles 171 and 183 of the Revised Penal Code (RPC).
- Non-filing of her Statement of Assets, Liabilities, and Net Worth (SALN) for the years 1995, 1997, and 1998.
- Failure to disclose properties and vehicles in her SALN.
- Administ
- Criminal Charges: