**Facts:**
The case originates from a complaint filed by Gilda D. Daradal against Engr. Prudencio C. Quimbo for Sexual Harassment and Oppression in the Provincial Engineering Office of Catbalogan, Samar. Daradal alleged inappropriate advances by Quimbo, who retaliated against her refusal by assigning her demeaning tasks and removing her from the payroll. Quimbo contested these allegations as fictitious. Daradal attempted to withdraw her complaint, but the Ombudsman-Visayas denied the motion and, after due proceedings, found Quimbo guilty of Oppression, imposing a six-month suspension without pay.
Quimbo sought reconsideration from the Ombudsman-Visayas but was denied. He then filed a petition for review under Rule 43 of the Rules of Court with the Court of Appeals (CA), which reversed the Ombudsman-Visayas’ ruling, stating that the Ombudsman could only recommend rather than impose penalties.
The Ombudsman filed an omnibus motion for intervention and reconsideration, which the CA denied, leading to the Ombudsman petitioning the Supreme Court through a petition for certiorari under Rule 65 of the Rules of Court, challenging the CA’s decisions.
**Issues:**
1. Whether the CA erred in ruling that the Ombudsman lacks the authority to directly impose administrative penalties and is limited to making recommendations.
2. Whether the CA erred in denying the Ombudsman’s right to intervene in the proceedings on the ground of lacking legal interest.
**Court’s Decision:**
The Supreme Court granted the Ombudsman’s petition, emphasizing that the Ombudsman does possess the power to directly impose administrative penalties, as confirmed in previous jurisprudence (e.g., Ombudsman v. Apolonio). The Court clarified that statements suggesting the Ombudsman’s power as merely recommendatory, such as in Tapiador vs. Office of the Ombudsman, were obiter dictum and not binding jurisprudential doctrine. Furthermore, the Court recognized the Ombudsman’s legal interest to intervene in proceedings that could impact its decisions, as its role in administrative discipline and accountability is fundamental.
**Doctrine:**
The Supreme Court established that the Ombudsman has the authority to directly impose administrative sanctions on erring public officials or employees, beyond merely recommending actions to disciplining authorities. This power extends from the constitutional mandate and legislative enactments granting the Ombudsman broad powers to investigate, prosecute, and enforce the accountability of government officials.
**Class Notes:**
– The Ombudsman’s power to impose sanctions is direct and not merely recommendatory (citing Ombudsman v. Apolonio).
– Statements suggesting the Ombudsman’s powers are limited to recommendations (e.g., Tapiador vs. Office of the Ombudsman) do not constitute binding jurisprudence.
– The Ombudsman holds a vested legal interest in the outcome of legal proceedings affecting its decisions and has the right to intervene (citing Ombudsman v. De Chavez).
– Legal statutes or provisions relevant to this case include the Constitution, R.A. No. 6770 (The Ombudsman Act of 1989), and CSC Memorandum Circular No. 30, series of 1989.
**Historical Background:**
This case underscores the evolving understanding and clarification of the Ombudsman’s powers in the Philippine legal system. Initially construed as having a recommendatory role, successive judicial clarifications have affirmed the Ombudsman’s direct administrative disciplinary authority, highlighting its essential role in ensuring accountability and integrity within the public service sector. This case is instrumental in cementing the Ombudsman’s authority, reinforcing its mandate as the “protector of the people,” and underscoring its active involvement in the enforcement of laws against corrupt practices.
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