FACTS : The petitioners, former officers and trustees of the Bureau of Fire Protection Mutual Aid & Beneficiary Association, Inc. (BFPMBAI), filed criminal and administrative complaints before the Office of the Ombudsman against Fire Chief Superintendent Carlito S. Romero, then Officer-in-Charge of the Bureau of Fire Protection (BFP). They alleged that under a 2006 Memorandum of Agreement, the BFP was obligated to deduct BFPMBAI members' contributions from their salaries and remit the same to the association. However, in February 2013, Romero ordered the temporary suspension of payroll deductions and the withholding of remittances after a dispute arose over the legitimacy of BFPMBAI's Board of Trustees following the contested June 30, 2012 elections. Petitioners claimed that despite repeated demands, Romero refused to release the remittances unless he and his allied candidates were recognized as the association's officers, causing BFPMBAI financial losses and disrupting its lending and insurance operations. They accused Romero of violating Sections 3(e) and 3(f) of the Anti-Graft and Corrupt Practices Act, committing grave coercion under the Revised Penal Code, and administratively committing grave misconduct, oppression, grave abuse of authority, and conduct prejudicial to the best interest of the service.
Romero denied the accusations, asserting that the BFPMBAI elections were unresolved because the Committee on Elections issued a status quo ante order after serious irregularities, including the casting of votes for thousands of absent members. To protect the association's funds and avoid releasing them to the wrong claimants, he suspended the remittances and later filed an interpleader case before the Regional Trial Court to determine the rightful Board of Trustees. He maintained that his actions were done in good faith, without malice, and that the withheld funds were eventually reverted to the Bureau of the Treasury. The Ombudsman dismissed both the criminal and administrative complaints, finding that Romero had valid legal grounds to withhold the remittances pending judicial resolution of the leadership dispute, that filing an interpleader was an appropriate remedy, and that there was no evidence of bad faith, personal benefit, or corrupt motive. Petitioners' motion for reconsideration was likewise denied, prompting them to file a petition for certiorari before the Supreme Court, where they argued that Romero should have challenged the election through an intra-corporate controversy rather than withholding the remittances and claimed that the Ombudsman gravely abused its discretion, even alleging bias on the part of the Deputy Ombudsman due to his prior professional relationship with Romero.
ISSUE : WON public respondent committed grave abuse of discretion in dismissing both the criminal and administrative charges filed against private respondent
HELD : The Supreme Court dismissed the petition and upheld the Ombudsman's dismissal of the criminal charges against Romero. It first ruled that it had no jurisdiction over the administrative aspect of the case because the proper remedy to question the Ombudsman's dismissal of administrative charges is a petition before the Court of Appeals. Thus, the Court limited its review to the criminal aspect, specifically whether the Ombudsman gravely abused its discretion in finding no probable cause for violations of Sections 3(e) and 3(f) of the Anti-Graft and Corrupt Practices Act and Article 286 of the Revised Penal Code. The Court emphasized that while Romero may have lacked clear authority to suspend the remittances and his handling of the funds may have been legally flawed, these acts alone did not establish manifest partiality, evident bad faith, gross inexcusable negligence, or corrupt motive, which are essential elements of the offenses charged. His actions were motivated by the unresolved dispute over the legitimate BFPMBAI Board of Trustees and his intent to protect the association's funds pending judicial resolution through an interpleader case. Moreover, there was no evidence that Romero personally benefited from the withheld remittances, as the funds were reverted to the Bureau of the Treasury.
The Court likewise found no probable cause for violations of Section 3(f) of R.A. No. 3019 and grave coercion under Article 286 of the Revised Penal Code. Petitioners failed to substantiate their allegations that Romero withheld the remittances to force them to recognize him and his allies as BFPMBAI officers or that he employed threats, intimidation, or coercion. Their claims were supported only by bare allegations without documentary or testimonial evidence. The Court also rejected petitioners' accusations of bias against the former Deputy Ombudsman, noting that there was no proof that he influenced the Ombudsman's resolutions. Finding no grave abuse of discretion in the Ombudsman's determination that probable cause was lacking, the Court affirmed the dismissal of the criminal charges and reiterated its policy of non-interference with the Ombudsman's prosecutorial discretion absent clear arbitrariness or capriciousness.
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