Facts:
In 2016, Adelaida Yatco filed a complaint with the Office of the Ombudsman against Marlyn B. Alonte-Naguit (then Mayor of Biñan, Laguna), Walfredo R. Dimaguila, Jr. (then Vice Mayor), Virgilio M. Dimaranan (Municipal Accountant), and Angelita Alonalon (Municipal Treasurer). The complaint alleged violations of 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), Plunder, Grave Misconduct, Conduct Prejudicial to the Best Interest of the Service, and Dishonesty. The allegations pertained to the municipal purchase of property for expanding the municipal cemetery, claimed to be disadvantageous to the government and involved financial interest by Alonte-Naguit.
On August 17, 2017, the Ombudsman dismissed the complaint citing lack of probable cause and substantial evidence. The Ombudsman’s findings included that Alonte-Naguit had no financial interest in the transaction and that the purchase price reflected fair market value.
Yatco filed a motion for reconsideration, which was denied on April 10, 2018. Consequently, Yatco filed a petition for certiorari under Rule 65 before the Court of Appeals (CA), arguing that since the Ombudsman consolidated the administrative and criminal decisions, she had opted to seek remedy from the CA as a whole.
Dimaguila moved to dismiss the petition citing lack of jurisdiction, which Yatco opposed, referencing the case of *Cortes v. Office of the Ombudsman*. The CA dismissed the petition regarding the criminal aspect, contending it had jurisdiction only over administrative disciplinary cases from the Ombudsman.
Issues:
1. Whether the Court of Appeals correctly dismissed Yatco’s petition for certiorari for lack of jurisdiction over the criminal aspect of Ombudsman decisions.
2. Whether the CA erred in interpreting the ruling in *Cortes* regarding jurisdiction over consolidated decisions involving both administrative and criminal complaints by the Ombudsman.
Court’s Decision:
1. **Jurisdiction Over Criminal Aspect**:
– The Supreme Court affirmed the CA’s dismissal of Yatco’s petition concerning the criminal aspect. Jurisprudence establishes that the CA’s jurisdiction extends only to administrative disciplinary rulings by the Ombudsman, and that the proper venue to assail criminal findings (via Rule 65) is the Supreme Court.
2. **Interpretation of *Cortes***:
– The petitioner misinterpreted *Cortes*. The Court clarified that while administrative aspects of decisions by the Ombudsman (when the right to appeal is available) can be challenged via Rule 43 petitions before the CA, the criminal aspects must be challenged via Rule 65 petitions directly before the Supreme Court. The consolidation of the Ombudsman’s resolutions did not alter the appropriate legal remedies applicable to the administrative and criminal components individually.
Doctrine:
1. The Court of Appeals’ jurisdiction is limited to administrative disciplinary cases from the Ombudsman.
2. The appropriate remedy for challenging the Ombudsman’s criminal findings on probable cause is a Rule 65 petition filed with the Supreme Court.
3. When challenging consolidated Ombudsman resolutions on administrative and criminal charges, procedural remedies corresponding to the nature of the charges must be followed separately (administrative as appealable to the CA under Rule 43, or as unappealable reviewed under Rule 65 to the CA; criminal reviewed under Rule 65 to the Supreme Court).
Class Notes:
– *Anti-Graft and Corrupt Practices Act* (RA 3019): Addresses corrupt practices among public officials.
– *Code of Conduct and Ethical Standards for Public Officials and Employees* (RA 6713): Prescribes standards for ethical behavior for public employees.
– *Rule 65 (Certiorari)*: Remedy for questioning tribunals acting with grave abuse of discretion amounting to lack or excess of jurisdiction.
– *Rule 43*: Governs appeals from decisions of quasi-judicial agencies to the CA.
– *Hierarchy of Courts*: Criminal aspect of Ombudsman rulings must be petitioned under Rule 65 to the Supreme Court, administrative aspect either appealed under Rule 43 to CA or reviewed under Rule 65 to CA if unappealable.
Historical Background:
This case highlights the procedural intricacies in the Philippine legal system regarding the proper venues and methods for challenging different aspects of Ombudsman decisions. It underscores the delineation between criminal and administrative remedies, ensuring that the unique procedural rules governing each type are strictly adhered to, supporting the broader judicial and quasilegislative approach to administrative justice within the Philippines.
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