Facts:

The case originated from an administrative complaint filed by private respondents Jesiela Antiporta and Aida Salmeo against Dr. Ramon Y. Alba, who was then the Director III of the Department of Education, Culture and Sports (DECS). The complaint was lodged with the Office of the Ombudsman for Mindanao, alleging that Dr. Alba violated the Code of Conduct and Ethical Standards for Public Officials and Employees (R.A. 6713).

The private respondents were among twenty-five graduating students of the Arriesgado Institute of Medical Sciences Foundation, Inc. (AIMSFI) in Tagum, Davao, who sought Dr. Alba's intervention regarding a dispute with the school concerning certain policies. On March 20, 1994, Dr. Alba scheduled a meeting with the students at the DECS Office in Davao City. However, instead of meeting with the students, he met with the owners of AIMSFI, the Arriesgado spouses, who did not have a prior appointment. This led to the students waiting for several hours without being attended to.

Feeling discriminated against, the students contacted the Deputy Ombudsman for Mindanao, Cesar E. Nitorreda, who visited the DECS Office to admonish Dr. Alba for not meeting with both parties simultaneously. Following this, Dr. Alba conducted a conference between the students and the school owners.

On March 29, 1994, Dr. Alba submitted a report claiming he had facilitated an amicable settlement. However, the students' affidavit-complaint contradicted this, stating they were barred from taking their final examinations and participating in graduation due to the dispute. They accused Dr. Alba of bias in favor of the school owners during the conference.

Dr. Alba denied the allegations, asserting that he met with the school owners first to understand the situation better before addressing the students. He also claimed that the students' inability to take their final exams was due to their failure to settle obligations with the school.

The Office of the Ombudsman found Dr. Alba guilty of violating several provisions of R.A. 6713, concluding that he acted with partiality towards the school owners and against the students' interests. Consequently, he was suspended for thirty days without pay.

Dr. Alba's motion for reconsideration was denied, prompting him to file a petition for certiorari with the Supreme Court, which was initially dismissed as moot. However, upon realizing the petition was filed within the suspension period, the Court decided to address the merits of the case.

Legal Issues:

  1. Whether the provisions of Section 27 of R.A. 6770 (Ombudsman Act of 1989) and Section 7, Rule III of Administrative Order No. 07, which state that certain decisions of the Ombudsman are final and unappealable, are constitutional and do not violate the right to due process.

  2. Whether the thirty-day suspension imposed on Dr. Alba was in accordance with valid law and due process, supported by substantial evidence, and not arbitrary or a grave abuse of discretion.

Arguments:

  • Petitioner (Dr. Alba):

    • Argued that the lack of an appeal process in the Ombudsman’s decision deprived him of property without due process.
    • Contended that the suspension was not substantiated by evidence and that he was not given a fair opportunity to present his case due to the failure of the Graft Investigating Officer to call for another preliminary conference after both parties missed the first one.
    • Asserted that the joint-affidavit of desistance from the private respondents should have led to the dismissal of the case against him.

  • Respondents (Ombudsman):

    • Maintained that the right to appeal is not a natural right but a statutory privilege, and the essence of due process was satisfied as Dr. Alba had the opportunity to present his side through pleadings.
    • Argued that the Ombudsman’s findings were supported by substantial evidence and that the procedures followed were in compliance with due process requirements.
    • Emphasized that the Ombudsman has the authority to investigate and prosecute public officials independently, and the joint-affidavit of desistance did not negate the Ombudsman’s duty to pursue the case.

Court's Decision and Legal Reasoning:

The Supreme Court denied Dr. Alba's motion for reconsideration, affirming the findings of the Office of the Ombudsman. The Court held that:

  1. The provisions of the Ombudsman Act and the Administrative Order were constitutional, as the right to appeal is not an inherent right but a privilege that can be regulated by law. The Court reiterated that due process is satisfied when a party is given a fair opportunity to be heard, which was afforded to Dr. Alba through the submission of affidavits and counter-affidavits.

  2. The Court found that the Ombudsman had substantial evidence to support the conclusion that Dr. Alba acted with bias and partiality, thus justifying the suspension. The Court emphasized that factual findings of administrative agencies are generally accorded respect and finality due to their expertise in handling such matters.

  3. The Court also ruled that the joint-affidavit of desistance from the private respondents did not bind the Ombudsman, as the latter has the authority to investigate and prosecute public officials for acts that are illegal or improper, regardless of the parties' wishes.

Significant Legal Principles Established:

  • The right to appeal is not a natural right but a statutory privilege, and due process is satisfied when a party is given an opportunity to be heard.
  • The findings of fact by administrative agencies, particularly the Ombudsman, are given deference and finality due to their specialized knowledge and expertise.
  • The Ombudsman has the independent authority to investigate and prosecute public officials, and such authority cannot be undermined by the parties involved in the complaint.