GR 131399; (October, 2003) (Digest)
G.R. No. 131399 ; October 17, 2003
ANGELITA AMPARO GO, petitioner, vs. OFFICE OF THE OMBUDSMAN, INSURANCE COMMISSIONER EDUARDO T. MALINIS and NORBERTO F. CASTRO, respondents.
FACTS
Petitioner Angelita Amparo Go, representing Wear Me Garment Manufacturing Inc., filed insurance claims totaling ₱29.778 million with fourteen companies after a fire destroyed its factory in 1993. Dissatisfied with the insurers’ denial and perceived delays, she sought assistance from the Insurance Commission. After initial conciliation failed, she filed an administrative case (Adm. Case No. RD-156) before the Commission against the insurers for alleged unfair claim settlement practices under the Insurance Code. While this administrative case was pending, she also filed a civil case for specific performance with damages before the Regional Trial Court of Quezon City involving the same claims and parties.
ISSUE
Whether the Office of the Ombudsman correctly dismissed the criminal complaint for violation of Section 3(e) of R.A. No. 3019 (Anti-Graft Law) against Insurance Commissioner Eduardo Malinis and Hearing Officer Norberto Castro, based on their handling of the administrative case.
RULING
Yes. The Supreme Court affirmed the Ombudsman’s dismissal. For a successful prosecution under Section 3(e) of R.A. No. 3019 , the accused must act with manifest partiality, evident bad faith, or gross inexcusable negligence. The Court found no evidence of these elements in the respondents’ official actions. The Insurance Commission acted within its jurisdiction and regulatory mandate in handling the administrative complaint. The subsequent filing of a parallel civil case by the petitioner, which sought the same monetary relief, justified the Commission’s order to suspend the administrative proceedings to avoid conflicting rulings and a multiplicity of suits. This suspension was a valid exercise of procedural discretion to prevent forum-shopping and ensure judicial economy. The respondents’ actions were performed in the regular course of their official duties, and the petitioner failed to present substantial evidence of corrupt intent or gross negligence. The Ombudsman’s finding of no probable cause was thus upheld.