G.R. No. 171056 March 13, 2009
DINAH C. CASTILLO, Petitioner, vs. ANTONIO M. ESCUTIN, AQUILINA A. MISTAS, MARIETTA L. LINATOC, AND THE HONORABLE COURT OF APPEALS, Respondents.

FACTS

Petitioner Dinah C. Castillo, a judgment creditor of Raquel K. Moratilla, discovered that Raquel co-owned Lot 13713 in Lipa City. After verifying ownership through a DAR conversion order, a City Assessor’s Certification, and a Register of Deeds Certification confirming the lot was untitled, petitioner levied the property. She bought Raquel’s 1/3 share at a public auction on May 14, 2002, and had the relevant documents recorded in the Register of Deeds’ books on June 4, 2002. The City Assessor subsequently issued Tax Declaration No. 00942-A in her name for a 5,000-square-meter share. Later, petitioner discovered her tax declaration was cancelled without notice. Lot 13713 was declared to be overlapping with Lot 1-B, covered by TCT No. 129642 in the name of Francisco Catigbac. The title’s reverse side showed entries, including a Special Power of Attorney in favor of Leonardo Yagin (dated 1976 but inscribed June 26, 2002) and a Sale in favor of Summit Point Realty & Development Corp. (instrument dated July 22, 2002, inscribed July 25, 2002). On July 25, 2002, TCT No. 129642 was cancelled and TCT No. T-134609 was issued to Summit Realty. Petitioner filed a complaint before the Office of the Deputy Ombudsman for Luzon against public officers Antonio M. Escutin (Register of Deeds), Aquilina A. Mistas (Local Assessment Operations Officer), and Marietta L. Linatoc (Records Clerk), and private individuals Lauro S. Leviste II and Benedicto L. Orense of Summit Realty, for grave misconduct and violation of Section 3(e) of R.A. No. 3019. Petitioner alleged irregularities, including that the Deed of Absolute Sale to Summit Realty was defective, that Catigbac had long been dead thus extinguishing Yagin’s authority, and that Summit Realty was aware of Catigbac’s death based on its prior court petition. The Ombudsman dismissed the complaint, finding no substantial evidence of bad faith, gross negligence, or manifest partiality by the public respondents. The Court of Appeals affirmed the Ombudsman’s dismissal.

ISSUE

Whether the Court of Appeals erred in affirming the Ombudsman’s dismissal of the complaints for grave misconduct and violation of Section 3(e) of R.A. No. 3019 against the public respondents.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ Decision. The Court held that the Ombudsman’s findings were supported by substantial evidence and found no grave abuse of discretion. For the administrative charge of grave misconduct, the Court ruled that the public respondents’ actions were performed in the regular course of their duties. Register of Deeds Escutin’s act of registering the documents and issuing a new title was ministerial, and he had no duty to investigate the validity of the documents presented. City Assessor’s Office employees Mistas and Linatoc acted based on the submitted TCT and technical description to update tax records, which was also a ministerial duty. The Court found no proof of malicious intent or conscious wrongdoing. For the criminal charge under Section 3(e) of R.A. No. 3019, the Court found no evidence of manifest partiality, evident bad faith, or gross inexcusable negligence. The elements of causing undue injury or giving unwarranted benefits were not established. The public respondents performed their ministerial functions in good faith, relying on the face of the documents presented. The Court emphasized that the Ombudsman’s findings on factual matters are generally accorded respect and finality, and petitioner failed to prove that such findings were made with grave abuse of discretion.