GR 188056; (January, 2013) (Digest)
G.R. No. 188056 ; January 8, 2013
SPOUSES AUGUSTO G. DACUDAO AND OFELIA R. DACUDAO, Petitioners, vs. SECRETARY OF JUSTICE RAUL M. GONZALES, Respondent.
FACTS
Petitioners, investors allegedly defrauded by Celso Delos Angeles, Jr. and the Legacy Group of Companies, filed complaints for syndicated estafa with the Office of the City Prosecutor of Davao City. Subsequently, the Secretary of Justice issued Department Order (DO) No. 182, directing all prosecutors to forward pending cases against Delos Angeles, Jr., et al. to a DOJ Special Panel in Manila for consolidated handling. Pursuant to this order, the petitioners’ complaints were forwarded from Davao City to the DOJ Secretariat.
Aggrieved, petitioners filed a direct petition for certiorari, prohibition, and mandamus with the Supreme Court. They alleged that DO No. 182 constituted grave abuse of discretion, violated their constitutional rights to due process, equal protection, and speedy disposition of cases, and was an obstruction of justice. They also challenged a related DOJ Memorandum that exempted cases filed in Cagayan de Oro City from the consolidation order, claiming it violated equal protection.
ISSUE
The core issues were: (1) whether petitioners properly filed their petition directly with the Supreme Court; and (2) whether the Secretary of Justice committed grave abuse of discretion in issuing DO No. 182 and the related memorandum.
RULING
The Supreme Court dismissed the petition. On the procedural issue, the Court held that petitioners unduly disregarded the hierarchy of courts. The concurrence of original jurisdiction to issue writs among different courts does not grant litigants an unrestricted choice of forum. Direct resort to the Supreme Court is allowed only for special, important, or compelling reasons, which petitioners failed to demonstrate. The policy shields the Court from causes within the competence of lower courts and preserves its role as a court of last resort.
On the substantive issues, the Court found no grave abuse of discretion. The Secretary of Justice, as the executive officer with control and supervision over prosecutors, possesses the authority to issue orders for the efficient administration of justice, including the consolidation of related cases to ensure uniformity and avoid conflicting resolutions. DO No. 182 was a valid exercise of this administrative power. The exemption granted to Cagayan de Oro cases, based on a prior memorandum, did not violate equal protection as the classification had a reasonable basis and was not shown to be arbitrary. The order did not retroactively apply a new law but was a procedural directive for handling existing cases. The petitioners’ claims of violations of their constitutional rights were unsubstantiated.