FACTS:

In this case, petitioner conducted an investigation on an alleged scam involving the Public Estates Authority-Amari Coastal Bay Development Corporation. The investigation revealed that the scam was carried out through the issuance of checks that were deposited in various financial institutions. Petitioner issued an order directing private respondent, Lourdes Marquez, the branch manager of Union Bank of the Philippines, to produce bank documents for inspection relating to specific bank accounts. Private respondent failed to comply, stating that the accounts belonged to International Corporate Bank (Interbank), which merged with Union Bank in 1994. Private respondent explained that diligent efforts were made to locate the accounts, but they could not be identified since the checks were issued in cash or bearer forms. Petitioner deemed private respondent's explanation unacceptable and warned that her actions constituted disobedience to a lawful order and could be subject to punishment for indirect contempt. Petitioner ultimately ordered private respondent to produce the bank documents for inspection, and in case of non-compliance, to show cause why she should not be held in contempt and charged with obstruction. Instead of complying, private respondent filed a petition for declaratory relief in the Regional Trial Court (RTC) of Makati City. Private respondent sought a ruling on her rights and petitioner's power to inspect bank deposits. Petitioner moved to dismiss the petition, but the RTC denied the motion.

ISSUES:

1. Whether or not the Regional Trial Court has jurisdiction over the petition for declaratory relief filed by the private respondent.

2. Whether or not the Ombudsman has the authority to inspect and have access to bank accounts and records.

RULING:

1. Yes, the Regional Trial Court has jurisdiction over the petition for declaratory relief filed by the private respondent. The court held that the issues raised in the petition involve the interpretation and application of conflicting provisions of law, particularly the Law on Secrecy of Bank Deposits and the Ombudsman Act of 1989, which are within the competence of the regular courts to resolve.

2. Yes, the Ombudsman has the authority to inspect and have access to bank accounts and records. The court ruled that Section 15 (8) of the Ombudsman Act of 1989 explicitly grants the Ombudsman the power to examine and have access to bank accounts and records, subject to the provisions of the Law on Secrecy of Bank Deposits. The court emphasized that the power of the Ombudsman to investigate and prosecute cases within its jurisdiction should not be unduly hampered by the invocation of the law on bank secrecy.

PRINCIPLES:

• The regular courts have jurisdiction over petitions for declaratory relief involving the interpretation and application of conflicting provisions of law.

• The Ombudsman has the authority to inspect and have access to bank accounts and records, subject to the provisions of the Law on Secrecy of Bank Deposits.