Crispin Burgos D. Bariata filed criminal and administrative complaints before the Office of the Ombudsman against then Mulanay, Quezon Mayor Joselito A. Ojeda and his wife, Dulce Quinto-Ojeda. He alleged that the mayor failed to truthfully disclose several real properties, vehicles, business interests, and other assets in his Statements of Assets, Liabilities, and Net Worth (SALNs) for 2010–2013, constituting violations of Sections 7 and 8 of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act) and Sections 7, 8, and 9 of Republic Act No. 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees). Bariata likewise charged the respondents with falsification of public documents under Article 171(4) and perjury under Article 183 of the Revised Penal Code, claiming that the omissions concealed unexplained wealth.
The Ombudsman dismissed both the criminal and administrative complaints for lack of probable cause and lack of substantial evidence, finding that the questioned properties had plausible explanations and that there was no proof that the omissions were deliberate or intended to conceal ill-gotten wealth. Bariata's motion for reconsideration was denied, prompting him to file a Petition for Certiorari under Rule 65 before the Supreme Court, alleging that the Ombudsman committed grave abuse of discretion in dismissing the complaints.
Issue
Whether the Ombudsman gravely abused its discretion in dismissing the criminal and administrative complaints against Mayor Ojeda for alleged violations of R.A. No. 3019, R.A. No. 6713, and the Revised Penal Code, and whether a Rule 65 petition before the Supreme Court was the proper remedy to challenge the dismissal of both the criminal and administrative cases.
Held
The Supreme Court denied the petition and sustained the Ombudsman's dismissal of the complaints. The Court held that no grave abuse of discretion attended the Ombudsman's findings because the evidence failed to establish that Mayor Ojeda knowingly and intentionally concealed assets in his SALNs. The Court explained that R.A. No. 6713 requires public officials to submit a truthful SALN to promote transparency and accountability, while Sections 7 and 8 of R.A. No. 3019 penalize public officers who unlawfully acquire unexplained wealth or engage in corrupt practices. However, criminal liability cannot rest on mere discrepancies in a SALN; there must be competent evidence showing fraudulent intent, deliberate concealment, or unlawful acquisition of wealth. Likewise, the charges for falsification under Article 171(4) and perjury under Article 183 of the Revised Penal Code require proof that the accused knowingly made false statements under oath, which was not established in this case.
The Court further ruled that Bariata availed of the wrong remedy insofar as the administrative case was concerned. While a finding on probable cause in criminal cases may be challenged before the Supreme Court through a petition for certiorari under Rule 65 when grave abuse of discretion is alleged, the dismissal of an administrative complaint by the Ombudsman should be questioned before the Court of Appeals through the proper mode of review, depending on whether the decision is appealable or unappealable. The Court emphasized that although the Ombudsman may issue a joint resolution resolving both criminal and administrative complaints, each case retains its distinct nature and must be assailed through the remedy prescribed by the Rules of Court. Finding neither procedural nor substantive error on the part of the Ombudsman, the Court upheld the dismissal of all charges
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