AC 11550; (June, 2018) (Digest)
G.R. No. A.C. No. 11550, June 4, 2018
Manuel B. Trovela, Complainant, vs. Michael H. Robles, Assistant City Prosecutor; Emmanuel L. Obungen, Prosecutor II; Jacinto G. Ang, City Prosecutor; Claro A. Arellano, Prosecutor General; and Leila M. De Lima, Former Secretary, Department of Justice, Respondents.
FACTS
Complainant Manuel B. Trovela filed a disbarment complaint against several government prosecutors and the former Secretary of Justice. The complaint stemmed from the dismissal of his criminal complaint for estafa against certain individuals. Specifically, he charged Assistant City Prosecutor Michael H. Robles for issuing a resolution recommending dismissal for insufficiency of evidence, and prosecutors Emmanuel L. Obungen and Jacinto G. Ang for approving said recommendation. He further sought the disbarment of former Prosecutor General Claro A. Arellano and former Secretary Leila M. De Lima for alleged inordinate delay in resolving his petition for review and motion for reconsideration before the Department of Justice. The complainant alleged that the respondents committed grave errors of law and fact, gross negligence, and violated their duties as lawyers and prosecutors, thereby compromising the administration of justice.
ISSUE
Whether the Integrated Bar of the Philippines (IBP) has jurisdiction to investigate and discipline the respondent government lawyers for administrative offenses arising from the performance of their official duties.
RULING
The Supreme Court DISMISSED the administrative case against all respondents for lack of jurisdiction. The Court held that the Integrated Bar of the Philippines has no jurisdiction to investigate government lawyers charged with administrative offenses involving the performance of their official duties. The legal logic is anchored on the constitutional and statutory mandate of the Office of the Ombudsman. Under Section 13, Article XI of the 1987 Constitution and Republic Act No. 6770 (The Ombudsman Act of 1989), the Office of the Ombudsman is vested with primary administrative disciplinary authority to investigate and prosecute any act or omission of any public officer or employee, including government lawyers, when such act or omission appears to be illegal, unjust, improper, or inefficient. This jurisdiction encompasses all kinds of malfeasance, misfeasance, and nonfeasance committed during their tenure.
Applying this principle, the allegations in the complaint—namely, the prosecutors’ evaluation of evidence leading to a dismissal recommendation and the alleged delay by the DOJ officials in resolving appeals—are intrinsically connected to the respondents’ discharge of their official functions as government lawyers. Since the acts complained of relate to their official duties, the proper forum for administrative discipline is the Office of the Ombudsman or their superior authorities, not the IBP. The Court cited its precedent in Spouses Buffe v. Secretary Gonzales, which explicitly ruled that the IBP lacks jurisdiction over government lawyers for administrative offenses involving their official duties. Consequently, the disbarment complaint was dismissed for being filed in the wrong forum.