G.R. No. 199625. June 06, 2018.
JEROME R. CANLAS, PETITIONER, VS. GONZALO BENJAMIN A. BONGOLAN, ET AL., RESPONDENTS.

FACTS

Petitioner Jerome R. Canlas filed an administrative complaint before the Office of the Ombudsman against officers of the Home Guaranty Corporation (HGC), a government-owned corporation. The complaint alleged grave misconduct and violation of Section 3(g) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act) for entering into a contract grossly disadvantageous to the government. The charge stemmed from HGC’s sale of two parcels of land at the Manila Harbour Centre to Alfred Wong King Wai for P13,300 per square meter. Canlas alleged the sale price was significantly below the fair market value, comparing it to a 1999 sale of an adjoining lot for P22,000 per square meter, thereby causing massive government loss.
The Ombudsman dismissed the complaint, finding no substantial evidence of bad faith or gross disadvantage. It held that the HGC Board exercised its business judgment in good faith, considering the property’s encumbrances, the need for immediate liquidity, and the lack of other offers despite public bidding. The Court of Appeals affirmed the Ombudsman’s dismissal. Canlas then elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the Supreme Court can review and reverse the findings of the Office of the Ombudsman exonerating the public officers of administrative charges.

RULING

The Supreme Court denied the petition and affirmed the assailed rulings. The Court emphasized the limited scope of its review over administrative disciplinary cases resolved by the Ombudsman. The Ombudsman’s findings of fact, when supported by substantial evidence, are accorded respect and finality. The Court found no grave abuse of discretion in the Ombudsman’s conclusion that the HGC officers acted within their authority and in the regular performance of official duties. The decision to sell the property was a business judgment made by the HGC Board after due process, including publication and review by the Office of the Government Corporate Counsel. The alleged disparity in price, without proof of bad faith, does not automatically constitute a grossly disadvantageous transaction under the law.
Furthermore, the Court highlighted a critical procedural flaw: Canlas lacked legal standing to appeal the exoneration. He was not the complainant in a criminal aspect but a mere informant in an administrative case. Under established jurisprudence, a private complainant has no legal interest in the administrative liability of public officers and cannot appeal their exoneration. Only the Ombudsman, representing the state, can appeal such a decision. Since Canlas did not stand to be personally benefited or injured by the administrative outcome, he was not an aggrieved party entitled to seek relief from the Court. Thus, the petition was dismissed.