MILAGROS MANOTOK DORMIDO, PETITIONER, V. OFFICE OF THE OMBUDSMAN, ROSELLER DE LA PEÑA, ERNESTO ADOBO, JR., FELICITAS MANAHAN, AND ROSENDO MANAHAN, RESPONDENTS.
FACTS
Petitioner Milagros Manotok Dormido and respondents spouses Felicitas and Rosendo Manahan had disputing claims over Lot 823 of the Piedad Estate in Quezon City. The dispute was brought before the Lands Management Bureau (LMB), where respondent Ernesto Adobo, Jr. was the OIC-Director. Adobo sought the legal opinion of respondent Roseller de la Peña, then Undersecretary for Legal Affairs of the Department of Environment and Natural Resources (DENR). De la Peña issued a Memorandum dated July 6, 2000, stating that the government no longer retained ownership of Lot 823, that the title held by the Manotok family was void ab initio, and recommending that it was ministerial for the LMB to issue a deed of conveyance in favor of the spouses Manahan. Consequently, on October 30, 2000, Adobo issued Deed of Conveyance No. V-200022 conveying Lot 823 to the spouses Manahan. Aggrieved, Dormido filed a Complaint-Affidavit before the Office of the Ombudsman charging respondents with conspiracy and violation of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act). She alleged that respondents disregarded the existing Torrens title in the name of the Manotoks and that the validity of a Torrens title could only be questioned in a direct proceeding before the trial courts. The Ombudsman dismissed the complaint, holding that the main issue was the determination of who holds a valid title over the property, a matter over which it had no jurisdiction as it pertained to a civil action involving title to real property, which is within the exclusive original jurisdiction of the regional trial courts under Batas Pambansa Blg. 129. Dormido’s motion for reconsideration was denied.
ISSUE
Whether the Office of the Ombudsman committed grave abuse of discretion amounting to lack or excess of jurisdiction in dismissing Dormido’s criminal complaint for alleged violation of Section 3(e) of R.A. No. 3019.
RULING
No, the Office of the Ombudsman did not commit grave abuse of discretion. The Petition for Certiorari was dismissed and the Ombudsman’s Orders were affirmed. The Supreme Court held that Dormido’s petition failed to allege acts constituting grave abuse of discretion by the Ombudsman; her arguments merely pointed to alleged errors of judgment, not errors of jurisdiction. Grave abuse of discretion implies a capricious, whimsical, arbitrary, or despotic exercise of judgment equivalent to lack of jurisdiction. The Ombudsman correctly dismissed the complaint under Section 20 of Republic Act No. 6770 (The Ombudsman Act of 1989), which allows the Ombudsman to decline investigation if the complainant has an adequate remedy in another judicial body or if the complaint pertains to a matter outside its jurisdiction. The core issue necessitated a determination of who between the Manotoks and the Manahans had valid title to Lot 823, a question exclusively within the jurisdiction of the regional trial courts. Furthermore, the Supreme Court noted that in a related case, Manotok IV v. Heirs of Homer L. Barque, it had already declared both the Manotok title and the Deed of Conveyance issued to the Manahans null and void, and declared Lot 823 as belonging to the National Government. Thus, there was no clear showing of arbitrariness in the Ombudsman’s dismissal of the complaint.
