Case Summary (G.R. No. 244775)
Key Dates and Procedural History
- 2016: Petitioner filed the complaint with the Ombudsman.
- August 17, 2017: The Ombudsman issued a Joint Resolution dismissing the complaint for lack of probable cause and substantial evidence.
- April 10, 2018: The Ombudsman denied petitioner’s motion for reconsideration.
- July 6, 2020: The Supreme Court decided the petition for review on certiorari from the Court of Appeals.
- February 7, 2019: The Court of Appeals issued a Resolution dismissing the petition for certiorari regarding the criminal aspect of the case for lack of jurisdiction.
Applicable Law and Jurisdictional Issues
The case involves the rules on judicial review and remedies against the Ombudsman's decisions under the 1987 Philippine Constitution and related laws, specifically:
- Republic Act No. 6770 (Ombudsman Act),
- Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act),
- Republic Act No. 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees),
- Rules of Court (Rule 43 for appeal; Rule 65 for certiorari),
- The jurisprudential distinction between administrative and criminal cases before the Ombudsman,
- Jurisdiction of the Supreme Court and Court of Appeals over these matters.
Facts and Findings of the Ombudsman
The Ombudsman, after investigation, dismissed the complaint citing lack of probable cause and insufficient evidence. It held that Mayor Alonte-Naguit had no direct or indirect financial interest since the portion purchased did not include her mother’s estate; the purchase price was fair and not disadvantageous to the government. The Ombudsman also ruled that the plunder charge failed because the accumulation of ill-gotten wealth of at least 50 million pesos was not established. It found no substantial basis for administrative liability against the respondents.
Petitioner’s Immediate Recourse and Motion
Petitioner filed a motion for reconsideration, which was denied. She subsequently filed a petition for certiorari under Rule 65 before the Court of Appeals, challenging the entire Ombudsman ruling, as the decision consolidated both criminal and administrative aspects of the complaints.
Motion to Dismiss and CA Resolution
Respondent Dimaguila moved to dismiss the petition at the Court of Appeals on the ground that it lacked jurisdiction over the criminal aspect of the case. The Court of Appeals agreed, ruling that it had jurisdiction only over administrative disciplinary cases, and not over criminal or non-administrative cases emanating from the Ombudsman. It clarified that the petitioner misconstrued the earlier ruling in Cortes v. Office of the Ombudsman regarding alternative remedies in consolidated cases and dismissed the criminal aspect of the petition.
Issue Before the Supreme Court
The Supreme Court was called upon to determine whether the Court of Appeals correctly dismissed the petition for certiorari as to the criminal aspect of the case from the Ombudsman.
Supreme Court's Analysis on Remedies for Ombudsman Decisions
The Court affirmed established jurisprudence governing remedies against Ombudsman rulings:
Administrative Charges: The Ombudsman Act (Section 27) provides that orders imposing penalties of public censure, reprimand, or suspension not exceeding one month’s salary are final and unappealable. Rulings exonerating respondents are also final and unappealable by implication. However, such final decisions are still subject to judicial review via certiorari under Rule 65, to be filed with the Court of Appeals.
Appealable administrative decisions—that is, those imposing penalties beyond the above threshold—may be appealed to the Court of Appeals under Rule 43 within 15 days.
Criminal Charges: The remedy against Ombudsman resolutions involving criminal cases, such as findings of probable cause, is a petition for certiorari under Rule 65. Importantly, such petitions must be filed directly with the Supreme Court, not the Court of Appeals.
The Supreme Court traced its jurisprudence from Fabian v. Desierto through Gatchalian v. Office of the Ombudsman and other cases, consistently holding that:
- The Court of Appeals' jurisdiction over Ombudsman cases is limited to administrative disciplinary decisions.
- Criminal aspects fall outside the CA’s jurisdiction and are under the exclusive original jurisdiction of the Supreme Court for certiorari actions.
- Consolidated decisions of the Ombudsman resolving both criminal and administrative complaints do not change the nature of the remedy or the proper forum.
Clarification on the Alleged "Alternative Remedies" in Consolidated Cases
Petitioner maintained that based on the CA’s ruling in Cortes, an aggrieved party has a choice to file either a petition for review under Rule 43 with the Court of Appeals or a petition for certiorari under Rule 65 directly with the Supreme Court when the Ombudsman consolidates administrative and criminal complaints. The Supreme Court rejected this interpretation, explaining:
- Petitioner did not comply with either of these alternative remedies correctly since she filed a Rule 65 certiorari petition with the Court of Appeals covering both aspects.
- The statement in Cortes should be understood narrowly and does not modify the settled rule distinguishing remedies for administrative and criminal aspects.
- Consolidation of cases is a procedural matter and does not affect the nature of the remedies or the jurisdiction of the courts.
- The remedies remain mutually exclusive depending on the nature of each charge.
Jurisprudential Precedents Affirming the Correct Procedure
The Court cited cases such as:
- Golangco v. Fung: The CA exceeded jurisdiction when reviewing Ombudsman criminal decisions.
- Tirol, Jr. v. Del Rosario: Remedy against Ombudsman decisions on criminal cases is certiorari under Rule 65 before the Supreme Court.
- Estrada v. Desierto: Clarification that certiorari cases invoking Supreme Court jurisdiction under Rule 65 for criminal aspects cannot be appealed first to CA.
- Joson v. Ombudsman: Distinction between remedies for criminal and administrative aspects, especially in consolidate
Case Syllabus (G.R. No. 244775)
Facts of the Case
- In 2016, petitioner Adelaida Yatco filed a complaint with the Office of the Ombudsman against four officials of Biñan, Laguna, including then Mayor Marlyn B. Alonte-Naguit, Vice Mayor Walfredo R. Dimaguila, Jr., Municipal Accountant Virgilio M. Dimaranan, and Municipal Treasurer Angelita Alonalon.
- The complaint alleged violations of Republic Act Nos. 3019 and 6713, charges of Plunder, Grave Misconduct, Conduct Prejudicial to the Best Interest of the Service, and Dishonesty related to the municipal cemetery property purchase.
- Petitioner contended that the transaction was disadvantageous to the government and that respondent Alonte-Naguit had a financial interest in the property purchased.
- The Ombudsman issued a Joint Resolution on August 17, 2017, dismissing the complaint for lack of probable cause and lack of substantial evidence, ruling that Alonte-Naguit had no financial interest and the purchase price was not disadvantageous.
- Petitioner’s motion for reconsideration was denied in a Joint Order dated April 10, 2018.
- Petitioner filed a petition for certiorari under Rule 65 of the Rules of Court with the Court of Appeals (CA), challenging the entire Ombudsman ruling consolidated for administrative and criminal aspects.
- Respondent Dimaguila moved to dismiss citing lack of jurisdiction of the CA over the criminal aspects, which petitioner opposed.
Proceedings Before the Court of Appeals
- On February 7, 2019, the CA issued a Resolution dismissing the petition for certiorari "as regards the criminal aspect of the case."
- The CA held that its jurisdiction extends only to administrative disciplinary cases decided by the Ombudsman, not to criminal or non-administrative cases.
- The CA ruled that petitioner misinterpreted the Cortes case, which did not provide for alternative remedies in consolidated administrative and criminal decisions.
- The CA referred to prior jurisprudence, including Duyon v. CA, holding that the CA exceeded jurisdiction when reviewing criminal aspects of Ombudsman decisions.
- Consequently, the dismissal of the petition for certiorari in criminal aspects was affirmed.
Issues Presented to the Supreme Court
- Whether the Court of Appeals correctly dismissed the petition for certiorari concerning the criminal aspect of the Ombudsman decision for lack of jurisdiction.
- The scope and applicability of jurisdiction and remedy rules in cases involving consolidated administrative and criminal charges by the Ombudsman.