Case Summary (G.R. No. 198241)
Applicable Law and Proceedings
This case is grounded in Republic Act No. 3019, known as the Anti-Graft and Corrupt Practices Act, and involves the procedural aspects outlined in Rule 65 of the Rules of Court relative to petitions for certiorari. The main focus was an alleged violation of Section 3(e) of RA 3019, which pertains to public officers causing undue injury to any party.
Background Facts
The dispute centers on Lot 823, previously covered by Transfer Certificate of Title (TCT) No. RT-22481. Dormido, along with the spouses Manahan, laid competing claims over this property at the Lands Management Bureau (LMB). Adobo, as OIC Director of Lands, consulted De la PeAa regarding these claims. In a July 6, 2000 Memorandum, De la PeAa opined that the government no longer retained ownership of Lot 823 and that the title held by Dormido's family was void. Consequently, a deed of conveyance favoring the spouses Manahan was executed on October 30, 2000.
Ombudsman’s Rulings
Dormido filed a complaint against the respondents in August 2010, accusing them of conspiracy and violation of RA 3019 for dismissing her ownership claims in favor of the spouses Manahan. The Ombudsman dismissed the complaint on October 15, 2010, asserting that the real issue was the determination of ownership, which fell outside its jurisdiction as outlined in Section 19 of Batas Pambansa Bilang 129 and Section 20 of RA 6770.
Motion for Reconsideration
Dormido sought reconsideration, contending that her complaint was criminal rather than civil and thus fell within the Ombudsman’s purview. The Ombudsman denied her motion on March 21, 2011, reinforcing that the resolution of ownership was critical for establishing any potential violations of RA 3019.
Petition for Certiorari
Dormido subsequently filed a Petition for Certiorari to contest the Ombudsman’s dismissal of her complaint. The Court examined whether the Ombudsman exercised grave abuse of discretion in the proceedings.
Court's Ruling and Legal Reasoning
The Court dismissed Dormido's petition, noting that findings of fact by fact-finding bodies cannot typically be challenged unless it demonstrates grave abuse of discretion. The petitioner’s arguments were characterized as mere disagreements with the Ombudsman’s assessment, which did not equate to jurisdictional errors.
Conclusion on Jurisdiction and Legal Findings
In affirming the Ombudsman’s orders, the Court held that it could not intervene in the factual determinations related to property ownership, nor could i
...continue readingCase Syllabus (G.R. No. 198241)
The Case
- This case involves a Petition for Certiorari under Rule 65 of the Rules of Court.
- The petition challenges the Orders of the Office of the Ombudsman dated October 15, 2010, and March 21, 2011.
- The Orders dismissed the Complaint filed by petitioner Milagros Manotok Dormido against respondents for violations of the Anti-Graft and Corrupt Practices Act (RA No. 3019).
Background Facts
- The dispute centers around Lot 823 of the Piedad Estate located in Quezon City.
- The lot was covered by Transfer Certificate of Title (TCT) No. RT-22481 (372302).
- Both Dormido and the spouses Manahan claimed ownership over Lot 823, leading to a complaint filed before the Lands Management Bureau (LMB).
- Ernesto Adobo, then the LMB's OIC Director of Lands, sought legal guidance from Roseller De la PeAa, Undersecretary for Legal Affairs of the Department of Environment and Natural Resources (DENR).
- De la PeAa issued a Memorandum on July 6, 2000, which concluded that the government no longer owned the lot and that the claims of Dormido’s family were void ab initio.
- Following this Memorandum, Adobo issued Deed of Conveyance No. V-200022 on October 30, 2000, transferring ownership of Lot 823 to the spouses Manahan.
- Dormido filed a Complaint with the Ombudsman on August 16, 2010, alleging conspiracy and violations