GR 118808; (December, 1996) (Digest)
G.R. No. 118808 December 24, 1996
JUDGE ANA MARIA I. DOLALAS, EVELLYN K. OBIDO AND WILBERTO B. CARRIEDO, petitioners, vs. THE HONORABLE OFFICE OF THE OMBUDSMAN-MINDANAO and BENJAMIN VILLARANTE, JR., respondents.
FACTS
Private respondent Benjamin Villarante, Jr. filed an administrative complaint before the Office of the Ombudsman-Mindanao against petitioners Judge Ana Maria I. Dolalas (Presiding Judge of the Municipal Circuit Trial Court of Kabasalan), Clerk of Court Evelyn K. Obido, and Clerk II Wilberto B. Carriedo. The complaint alleged miscarriage of justice, dishonesty, gross neglect of duty, and unnecessary delay in the administration of justice concerning Criminal Case No. 5881 for alarms and scandals filed against Villarante. He claimed that after submitting his counter-affidavit, no further proceedings like pre-conference or arraignment were conducted, causing unreasonable delay. Villarante alleged the case was maliciously filed to discourage him from pursuing his own complaint against police officers for abuse of authority.
The Ombudsman-Mindanao directed petitioners to submit counter-affidavits and denied their subsequent motion to dismiss and motion for reconsideration. Petitioners then filed this petition for certiorari with a prayer for a restraining order, arguing that the Ombudsman lacked jurisdiction over the complaint as it pertained to the court’s administrative supervision, which is exclusively vested in the Supreme Court.
ISSUE
Whether the Office of the Ombudsman has jurisdiction to investigate the complaint against the judge and court personnel for alleged undue delay in the disposition of a criminal case.
RULING
The Supreme Court ruled in favor of the petitioners, holding that the Ombudsman has no jurisdiction over the complaint. The Court emphasized that the complaint, though framed as potentially involving graft, was essentially administrative in nature. It pertained to the judge’s alleged failure to decide a case within the required period, which directly implicates compliance with the Code of Judicial Conduct and court rules on case disposition.
The legal logic is anchored on the doctrine of separation of powers and the explicit constitutional mandate. Under Article VIII, Section 6 of the 1987 Constitution , the Supreme Court has exclusive administrative supervision over all courts and their personnel. This power is plenary and cannot be intruded upon by another branch of government. The Ombudsman’s argument that it was investigating a possible violation of the Anti-Graft and Corrupt Practices Act (RA 3019) was untenable, as the core issue—determining whether there was undue delay—is an administrative matter falling solely within the Supreme Court’s disciplinary authority. To allow the Ombudsman to proceed would undermine judicial independence. Thus, the Ombudsman was directed to refer the complaint to the Supreme Court for appropriate action.