Office of the President v. Melchor Arthur H. Carandang

Summary

This case involves a challenge to the Office of the President's (OP) authority to discipline and dismiss a Deputy Ombudsman. Melchor Arthur Carandang was dismissed by the OP following a televised interview where he discussed alleged bank transactions of then-President Duterte, which the OP deemed a misuse of confidential information and an act of graft. Carandang argued that the OP lacked jurisdiction, citing the Second Gonzales Decision which declared the President's disciplinary power over Deputy Ombudsmen unconstitutional to protect the Office of the Ombudsman's independence. The Court of Appeals ruled in favor of Carandang, a decision affirmed by the Supreme Court. The Supreme Court held that the doctrine of stare decisis applies and that the President has no administrative authority over a Deputy Ombudsman. Furthermore, the Court found that Carandang's statements did not constitute sufficient grounds for dismissal. While the OP's decision was declared void, Carandang's term had already expired, meaning he could not be reinstated but was entitled to his retirement benefits and salaries up to the end of his term.