Case Summary (G.R. No. 134104)
Relevant Facts
Nenita R. Orcullo was elected as a City Councilor in Davao City in May 1995 and chaired the Committee on Women Welfare and Development. In September 1995, the city government appointed Virginia Yap Morales as the team leader for a study on women's welfare. However, due to financial constraints, Orcullo suspended the project in 1996, leading Morales to seek back pay for her services. In February 1998, the Deputy Ombudsman ordered Orcullo to pay Morales P70,800 in back wages, arguing that Morales had worked as a consultant despite the project being suspended.
Procedural History and Essentials of the Case
Orcullo contested the Deputy Ombudsman's order on the grounds that no employer-employee relationship existed and that the Ombudsman had no authority to issue the order. After her motion for reconsideration was denied, a graft investigator recommended filing a case against Orcullo under the Anti-Graft and Corrupt Practices Act. Orcullo subsequently filed a petition for certiorari against the Ombudsman's orders.
Jurisdictional Issues
The central issue was whether the Deputy Ombudsman had jurisdiction to order Orcullo to personally pay Morales. The Court found that claims for money against public officials of Davao City fall under the jurisdiction of the appropriate courts or the city government, but not the Office of the Ombudsman. The Ombudsman’s power to request assistance from government agencies does not extend to ordering payments for money claims.
Authority and Abuse of Discretion
The Court observed that the Deputy Ombudsman overstepped his authority by both ordering payment and approving the filing of a case against Orcullo. The Court emphasized that Orcullo acted within her capacity as a local legislator and did not exhibit bad faith in her refusal to pay Morales, considering Morales’s appointment was not under Orcullo’s direct employment. Thus, the grounds of th
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Case Background
- The case is a special civil action for certiorari with a preliminary injunction or temporary restraining order against the orders of the Deputy Ombudsman for Mindanao.
- Petitioner Nenita R. Orcullo was a city councilor of Davao City and chair of the Committee on Women Welfare and Development at the time of the case.
- Respondent Virginia Yap Morales was appointed as a team leader for a project aimed at formulating policies on women's welfare and development in Davao City.
- Financial constraints led to the suspension of the project that Morales was involved in, which triggered the conflict over back wages.
Initial Actions and Correspondence
- In September 1995, the Vice Mayor of Davao City appointed Morales as team leader for the women's welfare project.
- Orcullo suspended the project in 1996 due to budgetary issues.
- On February 18, 1997, Morales requested assistance from the Ombudsman to collect back wages, alleging that Orcullo unilaterally terminated her position and refused to pay for services rendered.
Petitioner’s Response
- Orcullo responded on March 20, 1997, clarifying that Morales was a volunteer who had been appointed to lead the study team and that she had signed a