The Supreme Court ruled that the Ombudsman did not commit grave abuse of discretion in dismissing a complaint against public officials accused of violating the Anti-Graft and Corrupt Practices Act. The Court emphasized that the Ombudsman’s decision was based on a reasoned evaluation that the central issue was a property dispute outside the Ombudsman’s jurisdiction. This decision underscores the principle that while the Ombudsman has the power to investigate graft, it must defer to the courts when the core issue involves property rights, especially when the alleged unwarranted benefit is tied to a contested ownership.

Property Rights vs. Graft: When Does the Ombudsman Defer to the Courts?

This case arose from a dispute over Lot 823 of the Piedad Estate in Quezon City. Milagros Manotok Dormido filed a complaint against Roseller de la Peña, Ernesto Adobo, Jr., and spouses Felicitas and Rosendo Manahan, alleging violations of Republic Act (RA) No. 3019, the Anti-Graft and Corrupt Practices Act. Dormido claimed that the respondents conspired to disregard her claims to the property, particularly the existence of the Manotoks’ titles. The Ombudsman dismissed the complaint, stating that the primary issue was the validity of the title to the property, which fell under the jurisdiction of the regional trial courts, not the Ombudsman.

The pivotal point of contention revolved around whether the Ombudsman abused its discretion in dismissing Dormido’s complaint. The Supreme Court reiterated the stringent standard for finding grave abuse of discretion, stating that it involves a “capricious and whimsical exercise of judgment” or an act “so patent and gross as to amount to an evasion of a positive duty.” The Court emphasized that certiorari is not a tool for reviewing facts or evidence but rather for correcting jurisdictional errors.

Dormido argued that the Ombudsman erred in relying on a previous case, *Ventura*, and in not finding a prima facie case for violation of Section 3(e) of RA 3019. She contended that the issuance of a deed of conveyance in favor of the Manahans, despite the Manotoks’ title, constituted an unwarranted benefit. The Court disagreed, stating that Dormido’s arguments pertained to errors of judgment, not jurisdiction. The Court found no evidence of arbitrariness on the part of the Ombudsman.

The Ombudsman’s decision was grounded in Section 20 of the Ombudsman Act of 1989, which states that the Ombudsman may not investigate if “[t]he complainant has an adequate remedy in another judicial or quasi-judicial body” or “[t]he complaint pertains to a matter outside the jurisdiction of the Office of the Ombudsman[.]” The Ombudsman reasoned that resolving the ownership issue was crucial to determining whether the respondents violated Section 3(e) of RA 3019. Since the Ombudsman lacks jurisdiction to adjudicate property disputes, the complaint was rightly dismissed.

The Court also affirmed the Ombudsman’s reliance on Office of the Ombudsman vs. Vda. De Ventura. In *Ventura*, the Court sustained the Ombudsman’s provisional dismissal of a case against a Department of Agrarian Reform (DAR) officer. In both cases, a key element was the requirement of finding an unwarranted benefit given to the party complained of. The Court noted that Adobo, as OIC-Director of Lands, granted the spouses Manahan the Deed of Conveyance only after formal investigation, hearings, and appreciation of evidence. Therefore, there were substantial grounds to award the property to the Manahans, making any allegation of unwarranted benefit premature at that stage.

The Supreme Court further highlighted the importance of avoiding multiplicity of suits. Allowing the Ombudsman to proceed on matters of ownership disputes would lead to conflicting judgments, confusion among litigants, and inefficient use of judicial resources. Thus, the Court underscored that the determination of property rights rests with the trial courts, not the Ombudsman.

The Court also considered the subsequent ruling in Manotok IV v. Heirs of Homer L. Barque, which nullified all titles and claims to Lot 823, including the Manotoks’ title and the Deed of Conveyance issued to the Manahans. However, this ruling came almost 10 years *after* the issuance of the Deed of Conveyance. Therefore, at the time Adobo issued the deed, there were reasonable grounds to believe the Manahans were entitled to it.

The ruling emphasizes the boundary between the Ombudsman’s prosecutorial powers and the judiciary’s role in resolving property rights. While the Ombudsman is empowered to investigate and prosecute graft and corruption, its jurisdiction does not extend to adjudicating ownership disputes. When a graft case hinges on the determination of property rights, and the alleged unwarranted benefit is directly tied to a contested ownership, the Ombudsman must defer to the courts. This ensures that property rights are properly adjudicated and that the Ombudsman’s focus remains on its core mandate of combating corruption within its jurisdictional limits.

FAQs

What was the key issue in this case?	The central issue was whether the Ombudsman committed grave abuse of discretion by dismissing a complaint alleging violation of the Anti-Graft and Corrupt Practices Act, where the underlying dispute involved conflicting claims to a property.
What is “grave abuse of discretion”?	Grave abuse of discretion means exercising judgment in a capricious, whimsical, or arbitrary manner, or evading a positive duty, indicating a lack of jurisdiction.
When can the Ombudsman dismiss a case based on jurisdiction?	The Ombudsman can dismiss a case if the complainant has an adequate remedy in another judicial or quasi-judicial body or if the matter falls outside the Ombudsman’s jurisdiction, such as cases involving title to real property.
What is Section 3(e) of RA 3019?	Section 3(e) of RA 3019 prohibits public officials from causing undue injury to any party or giving any private party unwarranted benefits, advantage, or preference in the discharge of their official functions.
What did the Ombudsman rely on to dismiss the complaint?	The Ombudsman relied on Section 20 of the Ombudsman Act of 1989, which allows the Ombudsman to dismiss cases falling under the jurisdiction of other bodies, such as property disputes under the jurisdiction of trial courts.
What was the significance of the Manotok IV v. Heirs of Homer L. Barque case?	While it ultimately nullified the titles of both parties, it came *after* the questioned deed of conveyance, and therefore, the Ombudsman had no basis to question the conveyance at the time it was made.
What is the practical implication of this ruling?	This case clarifies the limits of the Ombudsman’s jurisdiction in graft cases involving property disputes, ensuring that property rights are adjudicated in the proper forum and that the Ombudsman focuses on its core mandate of combating corruption within its jurisdictional limits.
What happens to the property dispute now?	The resolution of the underlying property dispute, if any, would need to be determined by the appropriate regional trial court.

This decision reinforces the balance between the Ombudsman’s role in combating corruption and the judiciary’s role in adjudicating property rights. It serves as a reminder that the Ombudsman’s prosecutorial powers are not without limits, and that deference to the courts is necessary when the core issue involves property ownership.

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: Dormido v. Ombudsman, G.R. No. 198241, February 24, 2020