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OFFICE OF OMBUDSMAN v. RUBEN ENOC

FACTS:

The respondents in this case were employed at the Office of the Southern Cultural Communities (OSCC) in Davao del Sur, with salaries below grade 27. They were charged with 11 counts of malversation through falsification and one count of violation of R.A. No. 3019. The Ombudsman filed the charges in the Regional Trial Court (RTC) of Digos, Davao del Sur as none of the respondents had the "rank" required to be tried in the Sandiganbayan. The respondents moved to quash the charges, relying on the ruling in Uy v. Sandiganbayan, arguing that the Ombudsman has no authority to prosecute graft cases in regular courts. The RTC granted the motion and dismissed the cases without prejudice to refiling. The Office of the Ombudsman filed a petition for review, arguing that the Ombudsman has broader investigatory and prosecutorial powers, not limited to cases cognizable by the Sandiganbayan. The Supreme Court, in its decision, held that the Ombudsman has the authority to investigate and prosecute all cases involving public officials and employees, regardless of rank and the nature of their acts or omissions. The Court set aside the RTC's order and reinstated the cases, directing the RTC to try and decide the same.

ISSUES:

  1. Whether the Ombudsman has jurisdiction to investigate, file information, and prosecute cases before regular courts.

  2. Whether the phrase "primary jurisdiction of the Office of the Ombudsman over cases cognizable by the Sandiganbayan" in Section 15(1) of R.A. No. 6770 is a delimitation of its jurisdiction solely to Sandiganbayan cases.

  3. Whether the authority of the Office of the Special Prosecutor to prosecute cases before the Sandiganbayan can be confused with the broader investigatory and prosecutorial powers of the Office of the Ombudsman.

RULING:

  1. The Ombudsman has authority to investigate and prosecute cases before regular courts as well as cases cognizable by the Sandiganbayan. The power to investigate and prosecute granted by law to the Ombudsman is plenary and unqualified, covering any act or omission of any public officer or employee that appears to be illegal, unjust, improper, or inefficient. The reference to cases cognizable by the Sandiganbayan in R.A. No. 6770 does not exclude the jurisdiction of the Ombudsman over cases involving public officers and employees cognizable by other courts. The jurisdiction of the Office of the Ombudsman should not be equated with the limited authority of the Office of the Special Prosecutor, which is confined to criminal cases within the jurisdiction of the Sandiganbayan.

PRINCIPLES:

  • The Ombudsman's power to investigate and prosecute is plenary and unqualified, covering any act or omission of any public officer or employee that appears to be illegal, unjust, improper, or inefficient.

  • The jurisdiction of the Ombudsman is not limited to cases cognizable by the Sandiganbayan, but encompasses all kinds of malfeasance, misfeasance, and non-feasance committed by public officers and employees.

  • The Office of the Special Prosecutor is a component of the Office of the Ombudsman and is limited to conducting preliminary investigations and prosecuting criminal cases within the jurisdiction of the Sandiganbayan. The Office of the Ombudsman, on the other hand, has broader investigatory and prosecutorial powers.

  • The authority of the Ombudsman to investigate and prosecute cases is not exclusive and can be shared with regular prosecutors.