The Supreme Court affirmed the Office of the Ombudsman’s decision to dismiss a criminal complaint against labor officials, emphasizing the principle of non-interference in the Ombudsman’s exercise of its investigatory and prosecutorial powers unless grave abuse of discretion is evident. This ruling underscores the wide latitude granted to the Ombudsman in determining probable cause and ensures that labor officials are not unduly prosecuted for decisions made within their official capacity, provided they act without manifest partiality, evident bad faith, or gross negligence. The decision reinforces the importance of procedural regularity in labor disputes and protects public servants from harassment suits based on mere disagreement with their judgments.

When Frustration Turns to Litigation: Did Labor Officials Abuse Their Power?

Romeo Araullo, after winning a labor case against Club Filipino for illegal dismissal, faced delays in the execution of the judgment award. Dissatisfied with the quashal of the writ of execution and the subsequent denial of his motion for reconsideration by the National Labor Relations Commission (NLRC), Araullo filed a criminal complaint against several labor officials, including Labor Arbiter Arden S. Anni (LA Anni) and NLRC Commissioners, alleging violations of Article 206 of the Revised Penal Code (RPC) and Section 3(e) of Republic Act (R.A.) No. 3019, the Anti-Graft and Corrupt Practices Act. Araullo argued that LA Anni issued an unjust interlocutory order by quashing the writ of execution and that the NLRC Commissioners supported this unjust order, causing him undue injury. The central legal question was whether the Office of the Ombudsman committed grave abuse of discretion in dismissing Araullo’s criminal complaint against these labor officials.

The Supreme Court, in its decision, reiterated its policy of non-interference with the rulings of the Office of the Ombudsman, except in cases of clear grave abuse of discretion. The Court emphasized that the determination of probable cause is a function that belongs to the Office of the Ombudsman, and its findings are generally not reviewable unless there is an allegation of grave abuse of discretion amounting to lack or excess of jurisdiction. The Court’s inquiry was limited to whether the Office of the Ombudsman committed such grave abuse in dismissing Araullo’s complaint. Grave abuse of discretion, according to jurisprudence, implies a capricious and whimsical exercise of judgment, equivalent to a lack of jurisdiction, or the exercise of power in an arbitrary or despotic manner. It must be so patent and gross as to amount to an evasion of a positive duty or a virtual refusal to perform the duty enjoined.

Probable cause, as defined by the Court, consists of facts sufficient to engender a well-founded belief that a crime has been committed and that the persons being charged are probably guilty. Araullo, as the complainant, was required to prove the elements of the crimes alleged and to clearly show the participation of each respondent. For the charge of violating Article 206 of the RPC, which penalizes the issuance of unjust interlocutory orders, it was necessary to demonstrate that the orders were unjust and were knowingly rendered or rendered through inexcusable negligence or ignorance. However, the Court agreed with the Office of the Ombudsman that LA Anni’s order to quash the writ of execution and the NLRC’s resolution affirming it were not unjust. The Court pointed to Rule XI, Section 4 of the 2005 NLRC Revised Rules of Procedure, which states:

Sec. 4. Computation during execution. – Where further computation of the award in the decision, resolution or order is necessary during the course of the execution proceedings, no writ of execution shall be issued until after the computation has been approved by the [LA] in an order issued after the parties have been duly notified and heard on the matter.

The quashal of the writ was deemed necessary to rectify LA Anni’s prior issuance, which occurred despite a pending motion for re-computation filed by Club Filipino. The Court found no evidence that the labor officials were motivated by anything other than the correction of this procedural error. Furthermore, the Court referenced its earlier ruling in Romeo R. Araullo v. Office of the Ombudsman, where it had already determined that LA Anni’s writ of execution was procedurally irregular. In that case, the Court stated:

There is no doubt that [LA] Anni’s July 29, 2008 Writ of Execution was procedurally irregular, as it pre-empted the NLRC Rules which require that where further computation of the award in the decision is necessary during the course of the execution proceedings, no Writ of Execution shall be issued until after the computation has been approved by the [LA] in an order issued after the parties have been duly notified and heard on the matter.

The Court emphasized that since the writ was issued in contravention of the law, it was irregular and defective, justifying LA Anni’s decision to quash it. Without probable cause against the labor officials, the charges against the private individuals (Atty. Balbin, Atty. Tabao, and Atty. De Leon) were also dismissed, as there was no conspiracy established. Similarly, the Court found no grave abuse of discretion in dismissing the complaint for violation of Section 3(e) of R.A. No. 3019. To establish a violation under this provision, the following elements must be present:

1. The accused must be a public officer discharging administrative, judicial, or official functions;
2. They must have acted with manifest partiality, evident bad faith, or inexcusable negligence; and
3. Their action caused undue injury to any party, including the government, or gave any private party unwarranted benefits, advantage, or preference.

The Court found that the second and third elements were lacking. There was no undue injury suffered by Araullo, and the labor officials’ actions were not performed with manifest partiality, evident bad faith, or inexcusable negligence. The Court cited People v. Atienza to define these terms:

There is “manifest partiality” when there is a clear, notorious, or plain inclination or predilection to favor one side or person rather than another. “Evident bad faith” connotes not only bad judgment but also palpably and patently fraudulent and dishonest purpose to do moral obliquity or conscious wrongdoing for some perverse motive or ill will. x x x [It] contemplates a state of mind affirmatively operating with furtive design or with some motive of self-interest or ill will or for ulterior purposes. “Gross inexcusable negligence” refers to negligence characterized by the want of even the slightest care, acting or omitting to act in a situation where there is a duty to act, not inadvertently but wilfully and intentionally, with conscious indifference to consequences insofar as other persons may be affected.

The Court concluded that Araullo failed to prove that the respondents were driven by any such motives, and the records indicated that the labor officials were simply adhering to the law and their procedural rules. The fact that Araullo’s counsel was not furnished with a copy of Club Filipino’s motion to quash the writ also did not support the criminal complaint, as the Court had previously determined that this failure did not prejudice Araullo’s rights.

FAQs

What was the key issue in this case?	The central issue was whether the Office of the Ombudsman committed grave abuse of discretion in dismissing a criminal complaint against labor officials who quashed a writ of execution in favor of Romeo Araullo.
What is the significance of the Office of the Ombudsman’s discretion?	The Supreme Court recognizes the wide latitude given to the Ombudsman in investigating and prosecuting public officials, intervening only when there is a clear showing of grave abuse of discretion. This ensures the Ombudsman’s independence in fighting corruption.
What are the elements of violating Section 3(e) of R.A. No. 3019?	The accused must be a public officer, acted with manifest partiality, evident bad faith, or inexcusable negligence, and their action caused undue injury or gave unwarranted benefits to a private party.
What constitutes “grave abuse of discretion”?	It implies a capricious and whimsical exercise of judgment, equivalent to a lack of jurisdiction, or the exercise of power in an arbitrary or despotic manner, so patent and gross as to amount to an evasion of a positive duty.
Why was the writ of execution quashed in this case?	The writ of execution was quashed because it was issued prematurely, before the Labor Arbiter had approved the computation of the judgment award, as required by the NLRC Rules of Procedure.
What did Araullo allege against the labor officials?	Araullo alleged that the labor officials issued unjust interlocutory orders, acted with manifest partiality, and caused him undue injury by quashing the writ of execution and delaying the enforcement of his judgment.
What is the standard for establishing probable cause in a criminal complaint?	Probable cause requires facts sufficient to engender a well-founded belief that a crime has been committed and that the persons being charged are probably guilty thereof.
What was the court’s basis for dismissing the charges against private individuals involved?	The charges against the private individuals were dismissed because there was no finding of probable cause against the labor officials, and no evidence of conspiracy to commit a criminal offense.

This case underscores the judiciary’s respect for the Ombudsman’s role in prosecuting public officials, while also setting a clear standard for when judicial intervention is warranted. It reinforces the need for concrete evidence of wrongdoing to overcome the presumption of regularity in official functions. For those seeking justice in labor disputes, this ruling highlights the importance of understanding procedural rules and ensuring that all legal avenues are exhausted before pursuing criminal charges.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Romeo R. Araullo v. Office of the Ombudsman, G.R. No. 194157, July 30, 2014