G.R. No. 240137 . September 09, 2020.
DEPARTMENT OF FINANCE-REVENYUE INTEGRITY PROTECTION SERVICE, PETITIONER, VS. OFFICE OF THE OMBUDSMAN AND MIRIAM R. CASAYURAN, RESPONDENTS.

FACTS

The Department of Finance-Revenue Integrity Protection Service (DOF-RIPS) filed criminal, administrative, and forfeiture charges against Miriam Casayuran, a Bureau of Customs employee. The charges stemmed from her alleged failure to file her Statement of Assets, Liabilities, and Net Worth (SALN) for certain years, her non-disclosure of a house and lot in Bulacan and a Nissan Sentra in her SALNs, and her acquisition of several properties and vehicles—including condominium units and cars—allegedly manifestly disproportionate to her government salary. The Ombudsman dismissed all charges in a Joint Resolution dated September 30, 2016, finding no probable cause for the criminal and forfeiture cases and no substantial evidence for the administrative case.
The Ombudsman ruled that the criminal charge for violation of the Code of Conduct and Ethical Standards (R.A. 6713) had prescribed, as it was filed beyond the eight-year prescriptive period from the date of the violation. Consequently, the related Anti-Graft charge was also dismissed. For the forfeiture case under R.A. 1379, the Ombudsman found that DOF-RIPS failed to account for Casayuran’s other possible income sources and loans, and thus did not sufficiently prove that her assets were unlawfully acquired. The administrative charges were dismissed for lack of substantial evidence. DOF-RIPS elevated the case via a Petition for Certiorari.

ISSUE

Whether the Office of the Ombudsman committed grave abuse of discretion in dismissing the criminal, administrative, and forfeiture complaints against respondent Miriam Casayuran.

RULING

The Supreme Court dismissed the petition and affirmed the Ombudsman’s rulings. The Court found no grave abuse of discretion, which implies a capricious or whimsical exercise of judgment equivalent to lack of jurisdiction. On prescription, the Court upheld the Ombudsman’s application of the eight-year period for violations of R.A. 6713, which are penalized by imprisonment of one month to six months. The complaint was filed in 2013 for violations from 1995-1998, well beyond the prescriptive period that began from the date of each violation.
Regarding the forfeiture case, the Court agreed with the Ombudsman that the petitioner failed to discharge its burden of proving that the properties were unlawfully acquired. The mere allegation of disproportion between assets and salary is insufficient; the State must first establish a prima facie case of unexplained wealth. The Ombudsman correctly noted that the petitioner did not consider other financial resources like loans, family support, or legitimate business income, which Casayuran was not obliged to prove at the preliminary investigation stage. The dismissal of the administrative charges for lack of substantial evidence was also sustained, as the factual findings of the Ombudsman are generally accorded respect and finality absent a clear showing of grave abuse.