G.R. No. 225565 , January 13, 2021
CAMP JOHN HAY DEVELOPMENT CORPORATION, REPRESENTED BY MANUEL T. UBARRA, JR., PETITIONER, VS. OFFICE OF THE OMBUDSMAN, ARNEL PACIANO D. CASANOVA, FELICITO C. PAYUMO, ZORAYDA AMELIA C. ALONZO, TERESITA A. DESIERTO, MA. AURORA GEOTINA-GARCIA, FERDINAND S. GOLEZ, ELMAR M. GOMEZ AND MAXIMO L. SANGIL, RESPONDENTS.

FACTS

On October 19, 1996, petitioner Camp John Hay Development Corporation (CJH Development) entered into a 25-year renewable Lease Agreement with the Bases Conversion Development Authority (BCDA). Subsequent agreements, including a Restructuring Memorandum of Agreement (RMOA) on July 1, 2008, were executed, wherein CJH Development acknowledged prior rental obligations and agreed to a payment plan. In return, BCDA promised to maintain a One-Stop Action Center (OSAC) to expedite the issuance of permits within 30 days. CJH Development failed to pay its rentals starting October 2009. On May 16, 2012, BCDA terminated the agreements due to CJH Development’s failure to pay outstanding rentals and other contractual breaches. CJH Development filed a Complaint-Affidavit before the Office of the Ombudsman against BCDA officials, alleging violations of Section 3(e) and (f) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act) and Sections 4(c) and 5(a) of Republic Act No. 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees). CJH Development claimed BCDA failed to perform its OSAC obligations, ignored settlement requests, filed a baseless estafa complaint, and published malicious statements. The BCDA officials countered that the OSAC was operational and delays were due to CJH Development’s failure to submit required documents, and that CJH Development committed various breaches including a double sale of a property. The Ombudsman dismissed the complaint for lack of probable cause, finding no proof of the elements of the alleged violations. CJH Development’s motion for reconsideration was denied.

ISSUE

Whether the Office of the Ombudsman committed grave abuse of discretion in dismissing the Complaint-Affidavit for lack of probable cause against the BCDA officials for alleged violations of Section 3(e) and (f) of R.A. No. 3019 and Sections 4(c) and 5(a) of R.A. No. 6713 .

RULING

The Supreme Court dismissed the Petition for Certiorari and affirmed the Ombudsman’s Joint Resolution and Joint Order. The Court held that the Ombudsman did not commit grave abuse of discretion. On the alleged violation of Section 3(e) of R.A. No. 3019 , the Court found that CJH Development failed to prove that the BCDA officials acted with manifest partiality, evident bad faith, or gross inexcusable negligence. The BCDA’s obligation to maintain the OSAC existed prior to the respondents’ assumption of office, and there was no showing that any delay or refusal was unjustified or motivated by ill will or a desire for pecuniary benefit. On the alleged violation of Section 3(f) of R.A. No. 3019 , the Court ruled that the provision requires proof of a deliberate refusal to act for an improper purpose, such as securing a material benefit or discriminating against a party. CJH Development failed to substantiate that the BCDA officials’ actions or inactions were motivated by such an improper purpose. The Court also found no merit in the allegations of violations of R.A. No. 6713 . The Court emphasized that the terms of the contract are binding on the parties and a lessor cannot be compelled to accept requests inconsistent with the contract. Furthermore, the Court reiterated that in a certiorari proceeding, it does not correct errors of judgment but only addresses jurisdictional errors or grave abuse of discretion amounting to lack or excess of jurisdiction, which was not present in this case.