- Petitioner
- Ruderic C. Marzo
- Respondent
- Regencia
- Citation
- G.R. No. 239262
- Court
- From Office of the Ombudsman (OMB) to Court of Appeals (CA) to Supreme Court (SC)
- Division
- First Division
- Decided
- August 1, 2018
Summary
This case involves the Office of the Ombudsman's violation of its own procedural rules regarding the finality of administrative decisions. The OMB initially exonerated respondent Celso G. Regencia from grave misconduct charges through a May 17, 2016 Joint Resolution. However, it subsequently granted petitioner Ruderic C. Marzo's motion for reconsideration via a March 29, 2017 Order, despite Administrative Order No. 7, Rule III, Section 7 providing that such exonerating decisions are final and unappealable. The Court of Appeals correctly ruled in favor of respondent's petition for certiorari and prohibition, finding the OMB Order to be a patent nullity. The Supreme Court affirmed this decision, emphasizing that administrative agencies must follow their own rules and that procedural rules should serve justice rather than defeat it. The case establishes important precedent regarding the finality of OMB administrative decisions and proper remedies for challenging ultra vires administrative actions.