**Facts:**
Ernesto Salvador and Guillermo Saldana, employees of the Sangguniang Panglungsod of Davao City, were investigated based on allegations of anomalous disbursements of the city’s PHP 1M legislative research fund. The investigation, conducted by the Office of the Ombudsman for Mindanao, resulted in a resolution finding sufficient evidence to prosecute them for violation of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act). A draft Information filed with the RTC of Davao City in Criminal Case No. 45,505-2000 charged both for causing undue injury to the City Government of Davao through fraudulent liquidation.
The Deputy Ombudsman endorsed the case to the City Prosecutor of Davao, who subsequently filed an Information detailing the charges. Both accused sought reconsideration of the Ladrera resolution and filed various motions in the RTC seeking abeyance of proceedings and recall of arrest warrants. When the trial court denied these motions, Salvador filed a Motion to Quash, citing a Supreme Court ruling in George Uy vs. Sandiganbayan, which held that only the prosecutor, not the Ombudsman, had authority to file information in regular courts.
On September 8, 2000, the RTC, adopting the George Uy ruling, issued an order dismissing the case. The Office of the Ombudsman subsequently moved for reconsideration, arguing that the decision in George Uy was not final and the Ombudsman’s broader investigatory and prosecutorial powers were not limited to cases cognizable by the Sandiganbayan. The trial court denied this motion on September 29, 2000. The Office of the Ombudsman then filed a certiorari petition with the Supreme Court.
**Issues:**
1. Whether the Office of the Ombudsman had authority to file the information for the violation of the Anti-Graft and Corrupt Practices Act before the RTC.
2. Whether the RTC had erred in dismissing the case based on the ruling in George Uy vs. Sandiganbayan.
**Court’s Decision:**
The Supreme Court ruled that the Office of the Ombudsman had the authority to file the information against Salvador and Saldana in the RTC, reversing the RTC’s dismissal of the case. The Court revisited its prior decision in George Uy vs. Sandiganbayan and concluded that the ruling limiting the Ombudsman’s prosecutorial powers to cases within the Sandiganbayan’s jurisdiction was incorrect.
**Issue by Issue Analysis:**
1. **Authority of the Ombudsman:**
– The Supreme Court clarified that the Ombudsman has both investigatory and prosecutory powers over any act or omission by public officers or employees that appears illegal, unjust, improper, or inefficient. These powers are not confined to cases cognizable by the Sandiganbayan but also extend to cases within the jurisdiction of regular courts.
2. **RTC’s Error in Dismissing the Case:**
– The RTC’s reliance on the George Uy ruling was premature and incorrect. The Office of the Ombudsman had filed a motion for clarification, and the Supreme Court eventually set aside its pronouncement in George Uy, reinforcing the Ombudsman’s broader jurisdiction.
– The RTC failed to consider the ongoing motion for further clarification filed by the Ombudsman and acted on incomplete precedent.
**Doctrine:**
The Supreme Court reiterated the broad investigatory and prosecutory powers of the Ombudsman under the 1989 Ombudsman Act (RA 6770). The power to prosecute crimes committed by public officers extends beyond the Sandiganbayan to cases within the jurisdiction of regular courts.
**Class Notes:**
– **Key Concepts:**
– Investigatory and prosecutory powers of the Ombudsman.
– Jurisdiction of the Sandiganbayan vs. regular courts.
– Legal interpretation of the Anti-Graft and Corrupt Practices Act.
– **Section 15 RA 6770:**
– Authorizes the Ombudsman to investigate and prosecute any illegal act/omission of public officials.
– **Section 11 RA 6770:**
– Specific powers of the Office of the Special Prosecutor to handle cases within Sandiganbayan jurisdiction.
– **George Uy Case Clarification:**
– Initially confined Ombudsman’s prosecutorial authority to Sandiganbayan jurisdiction.
– Later resolution by the Court expanded this authority, nullifying earlier restrictive interpretations.
**Historical Background:**
This case arose amidst legislative changes aimed at reorganizing the Office of the Ombudsman and the Sandiganbayan. The controversy specifically addressed the overlapping jurisdictional roles between these bodies and the Department of Justice, particularly in the investigation and prosecution of public officers. The case highlights the evolving judicial interpretation of statutory provisions governing these bodies’ powers.
Leave a Reply