Title
Office of the Ombudsman vs. Delijero, Jr.
Case
G.R. No. 172635
Decision Date
Oct 20, 2010
A public school teacher faced Grave Misconduct charges for inappropriate conduct with a student. The Ombudsman imposed dismissal, but the CA ruled it lacked jurisdiction. The Supreme Court held the Ombudsman has concurrent jurisdiction and mandatory sanction power, remanding the case to the CA for merits review.

Case Summary (G.R. No. 172635)

Facts of the Case

The respondent was administratively charged for Grave Misconduct based on a complaint initiated by Cleofas P. dela Cruz alleging inappropriate conduct towards her then 12-year-old daughter, Myra, who was a student in his Mathematics class. The allegations arose after Cleofas discovered that Pedro Delijero was courting Myra, evidenced by love letters and monetary gifts. Myra's affidavit described an occasion on April 7, 2003, where Delijero allegedly kissed her, prompting the administrative complaint.

Respondent's Defense

In his Counter-Affidavit, Delijero denied the allegations, asserting that Myra was infatuated with him and threatened him to reciprocate her feelings. He characterized their interaction as platonic, claiming Myra's actions were forcing him into a corner.

Administrative Proceedings and Ombudsman Decision

The Office of the Ombudsman, after evaluating the complaint, found Delijero guilty of Grave Misconduct and recommended his dismissal from public service, citing Section 46 (b) of the Revised Administrative Code of 1987. Delijero then sought reconsideration of the decision, resulting in the Ombudsman reaffirming its findings.

Court of Appeals Ruling

Delijero appealed the Ombudsman's decision to the Court of Appeals (CA), which ruled favorably for him, setting aside the Ombudsman’s decision. The CA held that the Ombudsman lacked jurisdiction over the administrative complaint against Delijero, as RA 4670 specified that such matters should first be addressed by an investigating committee of the Department of Education, Culture and Sports (DECS).

Issues on Jurisdiction and Authority

The CA concluded that the Office of the Ombudsman could not directly impose sanctions since the administrative proceedings should be conducted before the DECS. This decision hinged upon interpreting both the 1987 Constitution and RA 4670 regarding the jurisdiction over public school teachers.

Office of the Ombudsman's Authority

The petitioner contended that it held concurrent disciplinary authority over public school teachers alongside DECS. The Court recognized that while the Ombudsman has extensive investigatory powers, the specific rules governing administrative actions against teachers prioritize DECS's jurisdiction.

Principle of Estoppel

Further complicating the jurisdictional question, the Supreme Court observed that despite the Ombudsman's procedural impropriety, Delijero, by participating in

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