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Iglesias v. Ombudsman

The Supreme Court ruled that there was no denial of administrative due process in the case of Iglesias v. Office of the Ombudsman. Iglesias, a former government employee, was accused of failing to file statements of assets, liabilities, and net worth for years 2000 to 2002. While the Ombudsman added new findings not part of the original complaint against Iglesias in its resolution, denying her due process on those additional allegations, the Court found she was given opportunity to defend herself on the original charges regarding her SALN filings and could seek reconsideration of the Ombudsman's decision. Thus, while cautioning against adding new allegations, the Court found no overall due process

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703 views2 pages

Iglesias v. Ombudsman

The Supreme Court ruled that there was no denial of administrative due process in the case of Iglesias v. Office of the Ombudsman. Iglesias, a former government employee, was accused of failing to file statements of assets, liabilities, and net worth for years 2000 to 2002. While the Ombudsman added new findings not part of the original complaint against Iglesias in its resolution, denying her due process on those additional allegations, the Court found she was given opportunity to defend herself on the original charges regarding her SALN filings and could seek reconsideration of the Ombudsman's decision. Thus, while cautioning against adding new allegations, the Court found no overall due process

Uploaded by

Eric Karl Nicholas Aguilar
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Political Law; Constitutional Law; Administrative Due Process

IGLESIAS V. OFFICE OF THE OMBUDSMAN


GR NO. 180745 August 30, 2017; THIRD DIVISION; LEONEN, J. -
PONENTE

DOCTRINE: Administrative due process demands that the party being charged
is given an opportunity to be heard. An important component of due process is
the right of the accused to be informed of the nature of the charges against him
or her. A proper appraisal of the accusations would give the accused an
opportunity to adequately prepare for his or her defense. Otherwise,
substantial justice would be undermined.

FACTS:

Petitioner Iglesias was employed as Acting District Collector by the


Bureau of Customs in 200. It was alleged, among others, that she failed to file
her SALNs prior to the year 2002. As a consequence, the Department of
Finance, through Atty. Lean Acuna and Troy Francis C. Pizarro, filed a
Complaint-Affidavit against the petitioner before the office of the Ombudsman.

Iglesias filed her Counter-Affidavit with Countercomplaint in the


administrative case. Thereafter, she filed a Motion for Extension of Time to File
Counter-Affidavit in the criminal case to which she was unable to do so. The
Office of the Deputy Ombudsman for Luzon issued an order preventively
suspending Iglesias for six months while the investigation was ongoing. Graft
Investigation and Prosecution Officer I Robert C. Reñido (Prosecution Officer
Reñido) of the Office of the Deputy Ombudsman for Luzon issued a Joint
Resolution resolving the administrative and criminal cases in favor of Iglesias.
The Office of the Ombudsman, however, disapproved the Joint Resolution thru
its issued Resolution for failure to justify the substantial increase in her net
worth. Petitioner argued that she was denied of administrative due process for
the Resolution issued by the Ombudsman was based on new allegations that
were not included in the original Complaint which she was not informed of.

ISSUE:

Was there a denial of administrative due process?

RULING:

None. Administrative due process demands that the party being charged
is given an opportunity to be heard. Due process is complied with "if the party
who is properly notified of allegations against him or her is given an
opportunity to defend himself or herself against those allegations, and such
defense was considered by the tribunal in arriving at its own independent
Political Law; Constitutional Law; Administrative Due Process

conclusions." The Court stated that there was a violation of due process as
regards the accusation which were not included in the complaint. The Court
sternly reminds the Ombudsman that he cannot add new findings which were
not part of the original complaint. To do so would violate the right of the
accused to due process. However, the petitioner would still be liable for the
discrepancies, which were stated in the Complaint Affidavit, in her 2000 to
2002 SALNs. Moreover, she was able to move for reconsideration of the Office
of the Ombudsman Resolution. These circumstances preclude petitioner from
claiming that she was denied her right to due process.

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