G.R. No. 184083 ; November 19, 2013
WILLIAM C. DAGAN, Petitioner, vs. OFFICE OF THE OMBUDSMAN, represented by HON. ROGELIO A. RINGPIS, Graft Investigation and Prosecution Officer II, JAIME DILAG Y AGONCILLO, EDUARDO JOSE Y BAUTISTA, VERGEL CRUZ Y AQUINO, EDUARDO DOMINGO Y COSCULLUELA, ROGELIO TANDIAMA Y ARESPACOCHAGA, REYNALDO FERNANDO Y GALANG, AND ROMEO BUENCAMINO Y FRANCISCO, Respondents.

FACTS

Petitioner William C. Dagan, a racehorse owner, filed an administrative complaint before the Office of the Ombudsman against the former Chairman and Commissioners of the Philippine Racing Commission (Philracom). The complaint alleged multiple offenses, including graft, malversation, dishonesty, and grave misconduct. The specific charges included overpayment of prize money to racing clubs, improper hiring of a media consultant, oppressive scratching of the petitioner’s racehorses from an event, unauthorized promotional expenses and purchases, conflict of interest for a commissioner who owned racehorses, and neglect in implementing mandatory drug testing on racehorses.
The Office of the Ombudsman, in its Decision, exonerated all respondents from the administrative charges. It found the evidence insufficient to establish liability. Specifically, it ruled that the alleged overpayment was not supported by the Memorandum of Agreement, the scratching of the horses was a valid penalty for non-compliance with testing rules, the questioned disbursements were still subject to audit, the uniform purchase was a private transaction, and the ownership of racehorses by a commissioner in an honorary capacity did not constitute a conflict of interest under the law. The Ombudsman also found the charge regarding the failure to implement drug testing unsubstantiated.

ISSUE

Whether the Court of Appeals committed reversible error in dismissing the petitioner’s appeal and upholding the Ombudsman’s decision to exonerate the respondents from the administrative charges.

RULING

The Supreme Court denied the petition and affirmed the assailed resolutions. The Court emphasized that its power of review over decisions of the Office of the Ombudsman in administrative cases is limited. The Court will not interfere with the Ombudsman’s exercise of its investigatory and prosecutory powers, absent a clear showing of grave abuse of discretion amounting to lack or excess of jurisdiction. Grave abuse of discretion implies a capricious and whimsical exercise of judgment equivalent to an evasion of a positive duty or a virtual refusal to perform a duty enjoined by law.
In this case, the Court found no such abuse. The Ombudsman’s findings were based on its evaluation of the evidence presented, including documents and explanations from the respondents. The Ombudsman acted within its discretion in determining that the petitioner’s allegations were not substantiated by sufficient evidence to warrant administrative sanctions. The Court reiterated that it is not a trier of facts and will not re-evaluate the evidence, as factual findings of the Ombudsman, when supported by substantial evidence, are conclusive. Since the petitioner failed to demonstrate that the Ombudsman’s conclusions were arrived at arbitrarily or capriciously, the Court upheld the dismissal of the appeal.