G.R. No. 173277 - Office of the Ombudsman vs. Quimbo

Gilda D. Daradal, a clerk in the Provincial Engineering Office of Catbalogan, Samar, filed an administrative complaint against Engr. Prudencio C. Quimbo, the Provincial Engineer of Samar, for sexual harassment and oppression.
The complaint alleged that Quimbo made inappropriate sexual remarks and ordered Daradal to perform tasks typically assigned to male utility personnel after she refused his advances.
Quimbo denied the allegations, claiming they were fictitious and intended to embarrass him, asserting that he had validly exercised his discretion in ordering Daradal's detail.

On December 9, 1998, the Ombudsman-Visayas dismissed the sexual harassment charge but found Quimbo guilty of oppression, imposing a six-month suspension without pay.
Quimbo's motion for reconsideration was denied on April 15, 1999.

Quimbo appealed to the Court of Appeals (CA), which, on January 21, 2005, reversed the Ombudsman-Visayas' ruling, stating that the Ombudsman lacked the authority to directly impose sanctions and could only recommend penalties.
The CA emphasized that the proper disciplining authority was the Office of the Governor of the Province of Samar.

Following the CA's decision, the Ombudsman filed a motion for intervention and reconsideration, which the CA denied on May 2, 2006.
The CA ruled that the Ombudsman had no legal standing to intervene, as the real party in interest was Daradal, who did not seek reconsideration.

The Ombudsman filed a petition for certiorari under Rule 65, arguing that the CA had gravely abused its discretion by denying its motion to intervene and by misinterpreting its powers.
The Ombudsman asserted its right to seek redress as the disciplining authority and claimed that the CA's reliance on obiter dictum from previous cases was misplaced.

Quimbo contended that the Ombudsman lacked legal standing to intervene, emphasizing that the CA's decision was consistent with prevailing jurisprudence.

Whether the CA erred in declaring that the Ombudsman lacks the power to directly impose administrative penalties.
Whether the CA erred in denying the Ombudsman’s motion to intervene due to lack of legal interest.

The Court ruled that the Ombudsman has the authority to directly impose administrative penalties, rejecting the notion that its powers are merely recommendatory.
The Court cited previous rulings affirming the Ombudsman’s role as a protector of the people with the authority to enforce administrative sanctions.

The Court established that the Ombudsman has a clear legal interest in intervening in cases where its decisions are challenged, as it serves as a guardian of public accountability.
The Ombudsman’s role is distinct from that of a judge, as it is tasked w...continue reading