Case Summary (A.C. No. 4973)
Factual Background
On February 3, 1997, Aloro filed a complaint against Macalalag, claiming dishonesty linked to pension checks. Despite several orders urging Macalalag to respond, he failed to do so and requested a postponement during a preliminary conference. The case was resolved based solely on Aloro's evidence, revealing that Macalalag had endorsed and cashed Aloro's pension checks fraudulently. Aloro eventually received a dishonored check from Macalalag as a form of repayment. Despite Aloro's attempt to withdraw the complaint through an affidavit of desistance, the Ombudsman found Macalalag administratively liable, ordering his dismissal from service.
Procedural History
Following the Ombudsman's order, Macalalag attempted to appeal the decision. However, invoking the precedent set in Fabian vs. Desierto and adhering to Administrative Circular No. 99-2-01-SC, the Supreme Court dismissed his appeal, thereby leaving the Ombudsman’s ruling intact and final.
Legal Issues Presented
Macalalag subsequently initiated an action for annulment of judgment before the Court of Appeals on grounds of negligence and incompetence by his former counsel, claiming his day in court had been obstructed. The appellate court, however, dismissed his petition on grounds of lack of jurisdiction, emphasizing that under Section 9 (2) of B.P. Blg. 129, only judgments of Regional Trial Courts fall under its exclusive original jurisdiction.
Court of Appeals Decision
The Court of Appeals reiterated that the jurisdiction over actions for annulment is limited strictly to Regional Trial Court judgments, distinguishing between these and the orders from quasi-judicial bodies like the Ombudsman. Citing Fabian v. Desierto, the court asserted that jurisdiction over reviews of Ombudsman decisions lies exclusively with the Court of Appeals in compliance with Rule 43 of the 1997 Rules of Civil Procedure.
Arguments by the Petitioner
Macalalag contended that the term "Regional Trial Court" in Section 47 of the Rules of Court should encompass quasi-judicial bodies, but the appellate court noted that his interpretation lacked any legal foundation. It clarified that the annulment remedy remains constrained to judgments resulting from civil actions of Regional Trial Courts, and the checks and balances intended to prevent abusive resort to annulment were emphasized.
Finality of Decisions and Limitations
The judgment emphasizes that an action for annulment is an independent remedy and can only proceed under specific conditions such as e
...continue readingCase Syllabus (A.C. No. 4973)
Background of the Case
- The case revolves around the petition for review filed by Jessie Macalalag against the Ombudsman, Pablo Aloro, and the Court of Appeals regarding the jurisdiction over actions for annulment of the Ombudsman's decisions in administrative cases.
- The factual antecedents, as summarized by the appellate court, are largely undisputed and detail a complaint lodged by Pablo Aloro against Macalalag for dishonesty.
- On February 3, 1997, Aloro reported that Macalalag, an employee of the Philippine Postal Corporation, had endorsed and cashed his pension checks without authorization.
- Despite multiple orders directing Macalalag to respond, he failed to submit any answer or position paper.
- The investigator proceeded with the case based solely on the evidence provided by Aloro, leading to Macalalag's dismissal from service for administrative liability.
Procedural History
- Following the Ombudsman's decision to dismiss him, Macalalag sought reconsideration, which was denied.
- He then appealed to the Supreme Court via a petition for review on certiorari.
- This appeal was dismissed based on the precedent set in Fabian vs. Desierto and Administrative Circular No. 99-2-01-SC, which clarified that the Court of Appeals holds exc