G.R. No. 145368; July 1, 2002
SALVADOR H. LAUREL, petitioner, vs. HON. ANIANO A. DESIERTO, in his capacity as Ombudsman, respondent.

FACTS

Petitioner Salvador H. Laurel, former Vice-President, was designated as Chairman of the National Centennial Commission (NCC) by then President Fidel V. Ramos. The Ombudsman subsequently investigated him for alleged irregularities in connection with NCC projects. Laurel sought to dismiss the investigation, arguing he was not a “public officer” subject to the Ombudsman’s jurisdiction, contending the NCC was an ad-hoc, non-governmental body. The Supreme Court, in its main decision, ruled that Laurel, as NCC Chair, was indeed a public officer. He now files this Motion for Reconsideration, praying for a reversal and for the case to be referred to the Court En Banc.
In his motion, Laurel raises three primary arguments. First, he asserts the decision has “serious constitutional repercussions” because the NCC’s composition included members of the Cabinet, Congress, and the Supreme Court, who are constitutionally prohibited from holding other offices. Second, he invokes the principle of estoppel, claiming that the official acts of the highest government officials in designating members led him to believe the NCC was not a public office. Third, he argues the decision modified or reversed existing doctrines, which under the Constitution can only be done by the Court En Banc.

ISSUE

The core issue for reconsideration is whether the Supreme Court’s decision declaring petitioner Laurel a public officer as NCC Chair should be reversed or referred to the Court En Banc based on his arguments regarding constitutional repercussions, estoppel, and the modification of doctrine.

RULING

The Supreme Court denied the Motion for Reconsideration and the prayer for referral to the Court En Banc. The Court found all of Laurel’s arguments unmeritorious. On the constitutional issue, the Court clarified that the question before it was solely whether Laurel, as NCC Chair, was a public officer under the Ombudsman’s jurisdiction. Even assuming the designation of other prohibited officials to the NCC was unconstitutional, this fact does not alter the nature of Laurel’s own position or negate the rationale for classifying him as a public officer. His status is evaluated independently.
Regarding estoppel, the Court held the principle inapplicable. For estoppel to apply, the representation must be unequivocal and intentional, meant to be acted upon. It is “preposterous to suppose” that the President, Senate President, Speaker, and Supreme Court intended to mislead Laurel about the NCC’s nature just so he would accept the chairmanship. Furthermore, estoppel generally does not operate against the government in its sovereign capacity. On the final argument, the Court ruled that referral to the Court En Banc was unwarranted. The Court’s prior act of designating justices to the NCC was an administrative designation, not a “decision” articulating a “doctrine or principle of law” that the present division decision modified or reversed. The constitutional provision cited applies only to doctrines laid down in actual judicial cases. The motion was denied with finality.