GR 174297; (June, 2012) (Digest)
G.R. No. 174297 ; June 20, 2012
OFFICE OF THE OMBUDSMAN, Petitioner, vs. ROMEO A. LIGGAYU, Respondent.
FACTS
Respondent Romeo A. Liggayu, a manager in the PCSO Legal Department, received a cash advance to cover litigation expenses. To liquidate it, he submitted a disbursement voucher with supporting receipts. The PCSO Corporate Auditor issued a Notice of Disallowance for specific amounts, finding that a sales invoice from Nature’s Cafe for ₱2,204.00 was dubious as the establishment’s duplicate copy was blank and the corresponding official receipt was issued to a different entity. Another cash invoice from New Concepcion Cafe for ₱1,525.50 was found falsified, as the duplicate copy on file was only for ₱525.00. The PCSO General Manager formally charged Liggayu with dishonesty and gross misconduct and placed him under preventive suspension.
Liggayu denied the charges, asserting he had no control over the preparation of the establishments’ duplicate receipts and that he presumed the documents given to him were valid. He also filed a Petition for Certiorari with the RTC, which issued a writ of preliminary injunction ordering his reinstatement and suspending the PCSO’s investigation. Meanwhile, the PCSO Board endorsed the case to the Office of the Ombudsman. The Ombudsman proceeded, found Liggayu guilty, and dismissed him from service. Liggayu elevated the case to the Court of Appeals.
ISSUE
Whether the Office of the Ombudsman committed grave abuse of discretion in proceeding with the administrative case and finding Liggayu guilty despite the existing writ of preliminary injunction issued by the RTC.
RULING
The Supreme Court denied the Ombudsman’s petition and affirmed the Court of Appeals. The legal logic centers on the principle of judicial stability and the imperative to respect valid court orders. The RTC, in granting the preliminary injunction, had ordered the PCSO to suspend its investigation. While the case was later endorsed to the Ombudsman, the injunction remained in effect as it was directed at the PCSO officials who were the real parties-in-interest in the administrative charge. The Ombudsman, by taking over the case, effectively stepped into the shoes of the PCSO and was therefore equally bound by the injunction order.
The Court emphasized that the injunction was a legal obstacle that the Ombudsman could not simply ignore. The proper course of action was to seek the lifting of the injunction in the RTC, not to disregard it. By proceeding with the investigation and rendering a decision while the injunction was subsisting, the Ombudsman acted with grave abuse of discretion. This abuse warranted the annulment of its proceedings and decision. Consequently, the Court did not find it necessary to rule on the substantive merits of the administrative charges against Liggayu.