Title
Department of the Interior and Local Government vs. Gatuz
Case
G.R. No. 191176
Decision Date
Oct 14, 2015
DILG challenged RTC's voiding of Ombudsman's suspension order; SC ruled RTC lacked jurisdiction, upheld Ombudsman's immediate executory decisions.
suspension
implementation
noninterference

Case Summary (G.R. No. 191176)

Factual Background

In 2008 the respondent served as Barangay Captain of Barangay Tabang, Plaridel, Bulacan. On February 21, 2008, Felicitas L. Domingo filed an administrative complaint before the Office of the Ombudsman against the respondent for Abuse of Authority and Dishonesty, docketed as Administrative Case No. OMB-L-A-08-0126-C. The Deputy Ombudsman for Luzon found the respondent guilty of Dishonesty and imposed the penalty of three months suspension without pay in a decision approved December 8, 2008. The Deputy Ombudsman indorsed the decision to the Secretary of the Interior and Local Government for implementation on May 20, 2009, received by the Department on May 29, 2009. The respondent received a copy of the decision on June 30, 2009 and moved for reconsideration on July 7, 2009.

Administrative Correspondence and the DILG Memorandum

The Department deferred implementation pending the respondent’s motion for reconsideration and inquired of the Ombudsman about the effect of the Court’s then-recent ruling in Office of the Ombudsman v. Samaniego. The Ombudsman replied on September 22, 2009, invoking MC No. 1, Series of 2006, which provides that the filing of a motion for reconsideration or a petition for review does not stay implementation of Ombudsman decisions unless a temporary restraining order or writ of injunction is in force. Notwithstanding, on October 22, 2009, the DILG issued a memorandum directing the DILG Regional Director for Region III to implement the respondent’s suspension.

Trial Court Proceedings

The respondent filed a Petition for Declaratory Relief and Injunction with a Prayer for a Temporary Restraining Order or writ of Preliminary Injunction before the RTC on November 17, 2009, asking the RTC to construe his rights pending resolution of his motion for reconsideration and to restrain the Department from implementing the suspension. He invoked the Court’s decisions in Lapid and Samaniego to contend that the filing of a motion for reconsideration or appeal stayed execution of the Ombudsman’s decision. The RTC issued a TRO on November 20, 2009. After briefing, the RTC rendered judgment on January 18, 2010, declaring the October 22, 2009 DILG memorandum void and permanently prohibiting the Department from implementing the Ombudsman’s decision. The RTC relied on Samaniego, treated a motion for reconsideration as a precursor to an appeal, and did not address the Department’s jurisdictional objections.

Procedural Posture and Pleadings in the Supreme Court

The Department filed the present petition for review on certiorari on March 26, 2010, seeking reversal of the RTC decision. In response to the petition, the respondent filed a comment and also filed a Petition for Review of OMB-L-A-08-0126-C before the Court of Appeals on June 15, 2010. The Department argued before the Supreme Court that the RTC had no jurisdiction to issue injunctive relief in a declaratory relief action that effectively restrained a decision of the Ombudsman; that Samaniego lacked finality at the time because of a pending motion for reconsideration; and that MC No. 1, Series of 2006 controlled, providing that a motion for reconsideration does not stay implementation. The respondent countered that the RTC had jurisdiction, that filing an appeal or motion for reconsideration stayed execution pursuant to Lapid and Samaniego, and that the controversy was moot because he had appealed the Ombudsman’s decision to the Court of Appeals.

Issue Presented

Whether the Regional Trial Court had jurisdiction to entertain a petition for declaratory relief and injunction that sought to restrain the DILG from implementing a disciplinary decision of the Office of the Ombudsman, and whether the RTC properly restrained the Department’s implementation of the Ombudsman’s decision pending the resolution of a motion for reconsideration.

Ruling of the Supreme Court

The Supreme Court granted the petition, reversed, and set aside the RTC decision in Civil Case No. 808-M-2009. The Court held that the RTC lacked jurisdiction to entertain an action effectively directed against the execution of a quasi-judicial decision of the Ombudsman and erred in restraining the execution of that decision.

Legal Basis and Reasoning

The Court distinguished the present case from Marquez and Ibay, decisions in which the RTC’s declaratory relief jurisdiction was upheld because the petitions involved the investigatory power of the Ombudsman and the petitioners’ clash with other legal duties such as bank secrecy. By contrast, the DILG memorandum in this case was an implementation writ in the nature of execution of the Ombudsman’s disciplinary decision. The Court reiterated the settled principle that court orders and judgments, and the orders of quasi-judicial bodies, cannot be the subject matter of declaratory relief because such practice would permit a party to relitigate matters that are already the subject of judgment, thereby violating the doctrine of res judicata. The Court also invoked the doctrine of judicial stability or noninterference to emphasize that coordinate bodies of equal rank should not interfere with each other’s adjudicative processes and orders, particularly where an administrative adjudicative body has appellate recourse to the Court of Appeals.

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