G.R. No. 209608 February 13, 2019
Digital Paradise, Inc., represented by Federico Eugenio, Petitioner vs. Hon. Orlando C. Casimiro, in his capacity as the Overall Deputy Ombudsman, et al., Respondents

FACTS

Petitioner Digital Paradise, Inc. (DPI) filed criminal complaints before the Office of the Ombudsman against several police officers for Robbery with Force Upon Things, Incriminating Against Innocent Persons, Other Forms of Trespass, and Grave Coercion. DPI alleged that on September 13, 2011, the respondent police officers, without a search warrant, forcibly entered the warehouse DPI was leasing, ordered security personnel to lie face down, destroyed property, and planted boxes of allegedly hijacked electronic devices inside DPI’s unit while also taking some of DPI’s items.
The respondent police officers countered that they conducted a legitimate police operation based on a tip about hijacked electronics. They claimed that after flagging down a suspicious van for a traffic violation, they discovered stolen goods and pursued suspects who fled into DPI’s warehouse. Upon entry, they found more stolen items, leading to arrests. The Ombudsman dismissed DPI’s complaints, finding the police operation legitimate and that the officers acted in good faith in the performance of their duties. DPI filed this petition for certiorari, arguing the Ombudsman committed grave abuse of discretion.

ISSUE

Whether the Office of the Ombudsman committed grave abuse of discretion in dismissing the criminal complaints against the respondent police officers.

RULING

No. The Supreme Court dismissed the petition, upholding the Ombudsman’s findings. The Court emphasized that a petition for certiorari under Rule 65 is not a remedy for correcting errors of judgment but is solely for correcting errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction. Grave abuse of discretion exists when a tribunal acts in a capricious, whimsical, arbitrary, or despotic manner so patent and gross as to amount to an evasion of a positive duty or a virtual refusal to perform a duty enjoined by law.
The Court reiterated the well-established doctrine that the Ombudsman has full discretionary authority to determine whether a criminal case should be filed. Its findings on the existence of probable cause are generally not reviewable by the courts unless shown to have been made with grave abuse of discretion. In this case, DPI’s petition essentially questioned the Ombudsman’s assessment and weighing of evidence, which involved an inquiry into the investigative body’s appreciation of facts. The Court found that DPI failed to demonstrate that the Ombudsman’s dismissal was tainted with arbitrariness, bad faith, or a clear disregard of legal standards. The respondents’ detailed narration of a coordinated police operation provided a sufficient basis for the Ombudsman’s conclusion of good faith and absence of criminal intent. Since no grave abuse of discretion was proven, the Court had no authority to disturb the Ombudsman’s discretionary determination.