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Tag: Fabian v. Desierto

  • Finality of Ombudsman Decisions: When Absolution Means No Appeal

    In Barata v. Abalos, Jr., the Supreme Court clarified that decisions of the Ombudsman absolving a respondent of administrative charges are final and unappealable. This ruling reinforces the independence of the Ombudsman and streamlines administrative processes by preventing unnecessary appeals in cases where the respondent is exonerated. The decision underscores that while the right to appeal is a statutory privilege, it is not a natural right and must be exercised strictly within the bounds of the law. This case provides critical guidance on the scope and limitations of appealing decisions from the Office of the Ombudsman.

    When Justice Ends: Understanding Appeal Rights in Ombudsman Decisions

    The case arose from an administrative complaint filed by Evelio Barata against then Mandaluyong City Mayor Benjamin Abalos, Jr. Barata, representing the San Miguel Bukid Homeowners’ Association, alleged that Abalos failed to act promptly on requests related to a housing project. The Office of the Ombudsman dismissed the complaint, citing insufficient evidence, a decision Barata sought to appeal. This case highlights the importance of understanding the specific rules governing appeals from the Ombudsman, particularly in cases where a respondent is absolved of the charges. The Supreme Court’s decision clarifies the circumstances under which an Ombudsman’s decision is final and unappealable, providing a framework for future administrative cases.

    The central issue in Barata v. Abalos, Jr. revolves around the interpretation and application of Section 27 of Republic Act No. 6770, also known as The Ombudsman Act of 1989. This section outlines the effectivity and finality of decisions issued by the Office of the Ombudsman. Specifically, the law states:

    “SEC. 27. Effectivity and Finality of Decisions. – (1) All provisionary orders at the Office of the Ombudsman are immediately effective and executory.

    A motion for reconsideration of any order, directive or decision of the Office of the Ombudsman must be filed within five (5) days after receipt of written notice and shall be entertained only on any of the following grounds:

    (1) New evidence has been discovered which materially affects the order, directive or decision;

    (2) Errors of law or irregularities have been committed prejudicial to the interest of the movant. The motion for reconsideration shall be resolved within three (3) days from filing: Provided, That only one motion for reconsideration shall be entertained.

    Findings of fact by the Office of the Ombudsman when supported by substantial evidence are conclusive. Any order, directive or decision imposing the penalty of public censure or reprimand, suspension of not more than one month’s salary shall be final and unappealable.

    In all administrative disciplinary cases, orders, directives or decisions of the Office of the Ombudsman may be appealed to the Supreme Court by filing a petition for certiorari within ten (10) days from receipt of the written notice of the order, directive or decision or denial of the motion for reconsideration in accordance with Rule 45 of the Rules of Court.

    The above rules may be amended or modified by the Office of the Ombudsman as the interest may require.”

    The Supreme Court, in analyzing this provision, emphasized that the finality of decisions depends on the nature of the penalty imposed. If the penalty is public censure, reprimand, or suspension of not more than one month’s salary, the decision is final and unappealable. However, the Court also addressed the procedural aspect of appealing Ombudsman decisions, particularly in light of the ruling in Fabian v. Desierto. This landmark case altered the appellate route for administrative disciplinary cases from the Ombudsman, directing them to the Court of Appeals instead of the Supreme Court. The Court stated that:

    “Thus, appeals from decisions of the Office of the Ombudsman in administrative disciplinary cases should be brought to the Court of Appeals under the provisions of Rule 43. The only provision affected by the Fabian ruling is the designation of the Court of Appeals as the proper forum and of Rule 43 of the Rules of Court as the proper mode of appeal; all other matters included in said Section 27, including the finality or non-finality of decisions, are not affected and still stand.”

    Building on this principle, the Supreme Court considered Administrative Order No. 7, Section 7, Rule III, which explicitly states that when a respondent is absolved of the charge, the decision is final and unappealable. This rule, promulgated by the Ombudsman, reinforces the idea that acquittals should be treated differently from convictions in terms of appealability. The rationale behind this distinction lies in promoting administrative efficiency and preventing harassment through protracted litigation when no culpability has been established. The High Court said that:

    “The above-quoted provision explicitly provides that where the respondent is absolved of the charge, the decision shall be final and unappealable. Although the phrase ‘(W)hen the respondent is absolved of the charge’ is not one of those instances enumerated in Section 27 of R.A. 6770 wherein the decision shall become final and unappealable, it is implicit in Section 27, and with greater reason, that decisions of the Ombudsman absolving the respondent of the charge, should be final and unappealable.”

    It’s important to highlight that while the decision of the Ombudsman is generally final and unappealable when the respondent is absolved, this does not preclude the availability of judicial review through a petition for certiorari under Rule 65 of the Rules of Court. This remedy is available in cases of grave abuse of discretion, ensuring that the Ombudsman’s actions are subject to judicial scrutiny when necessary. The Supreme Court emphasized that:

    “Needless to state, in appropriate cases involving oppressive or arbitrary action, the complainant is not deprived of a legal recourse by certiorari under Rule 65 of the Rules of Court which apply suppletorily to the Rules of Procedures of the Office of the Ombudsman.”

    In the context of Barata v. Abalos, Jr., the Supreme Court found that the decision of the Ombudsman dismissing the administrative complaint against Abalos was indeed final and unappealable. Furthermore, even if an appeal were permissible, Barata’s petition was filed beyond the reglementary period, rendering it procedurally infirm. The Court observed that the failure to provide a right of appeal in certain cases does not constitute a denial of due process, as the right to appeal is statutory rather than constitutional. Thus, it must be exercised in accordance with the law. Here is a summary of the key arguments:

    Petitioner’s Argument Respondent’s Argument Court’s Reasoning
    The Ombudsman’s decision is appealable under Section 27 of R.A. 6770. The Ombudsman’s decision absolving the respondent is final and unappealable under Administrative Order No. 7. The decision absolving the respondent is final and unappealable. Appeal should be to the Court of Appeals, not the Supreme Court. The petition was filed out of time.

    The decision in Barata v. Abalos, Jr. also reinforces the principle that the procedural rules for appealing decisions must be strictly followed. The Court noted that Barata’s initial attempt to appeal to the Supreme Court, which was denied due to the Fabian ruling, did not toll the running of the period to file a petition for review with the Court of Appeals. This highlights the importance of correctly identifying the proper forum and mode of appeal within the prescribed timeframe. The case underscores the significance of adhering to procedural rules in administrative appeals.

    In conclusion, the Supreme Court’s decision in Barata v. Abalos, Jr. provides clear guidance on the finality and appealability of decisions from the Office of the Ombudsman. It affirms that decisions absolving a respondent of administrative charges are final and unappealable, subject only to judicial review via certiorari in cases of grave abuse of discretion. The ruling emphasizes the importance of understanding and adhering to the procedural rules governing administrative appeals and reinforces the independence and efficiency of the Ombudsman’s office.

    FAQs

    What was the key issue in this case? The key issue was whether a decision of the Ombudsman absolving a respondent of administrative charges is appealable. The Supreme Court ruled that such decisions are final and unappealable.
    What is Section 27 of R.A. 6770? Section 27 of R.A. 6770, also known as The Ombudsman Act of 1989, outlines the effectivity and finality of decisions issued by the Office of the Ombudsman. It specifies which decisions are final and unappealable and the procedure for appealing other decisions.
    What was the impact of the Fabian v. Desierto ruling? The Fabian v. Desierto ruling changed the appellate route for administrative disciplinary cases from the Ombudsman, directing them to the Court of Appeals instead of the Supreme Court. This decision ensured that appeals would be handled in the proper forum.
    When can a decision of the Ombudsman be appealed? A decision of the Ombudsman can be appealed if it imposes penalties such as suspension of more than one month’s salary or other sanctions beyond public censure or reprimand. The appeal must be filed within the prescribed timeframe.
    What is Administrative Order No. 7, Section 7, Rule III? This administrative order provides that when a respondent is absolved of the charge, the decision is final and unappealable. This rule reinforces the principle that acquittals should not be subject to unnecessary appeals.
    What recourse is available if the Ombudsman commits grave abuse of discretion? Even if a decision is generally final and unappealable, judicial review through a petition for certiorari under Rule 65 of the Rules of Court is available in cases of grave abuse of discretion. This ensures that the Ombudsman’s actions are subject to judicial scrutiny.
    Why is the right to appeal not considered a natural right? The right to appeal is statutory rather than constitutional, meaning it is granted by law and can be modified or limited by law. As such, it must be exercised in accordance with the law’s provisions.
    What was the outcome of Barata’s petition in this case? The Supreme Court denied Barata’s petition, holding that the Ombudsman’s decision was final and unappealable. Additionally, the Court noted that even if an appeal were permissible, Barata’s petition was filed beyond the reglementary period.

    This case serves as a reminder that understanding the nuances of administrative law and procedure is crucial for both public officials and citizens alike. Knowing when a decision is final and how to properly pursue an appeal can save time and resources while ensuring that justice is served.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: EVELIO P. BARATA v. BENJAMIN ABALOS, JR., G.R. No. 142888, June 6, 2001

  • Jurisdictional Boundaries: Understanding Appeals from the Ombudsman’s Decisions

    The Supreme Court in Villavert v. Desierto addressed the proper procedure for appealing decisions from the Office of the Ombudsman in administrative disciplinary cases. The Court clarified that Section 27 of Republic Act No. 6770 (The Ombudsman Act of 1989), which allowed direct appeals to the Supreme Court, was unconstitutional. This ruling means that appeals from the Ombudsman’s decisions must first be brought to the Court of Appeals, ensuring a consistent and constitutional approach to judicial review.

    Navigating the Appeal: When the Supreme Court’s Door Closes on Ombudsman Cases

    The case of Douglas R. Villavert v. Hon. Aniano A. Desierto arose from administrative charges against Villavert, a Sales & Promotion Supervisor at the Philippine Charity Sweepstakes Office (PCSO). He faced allegations related to unpaid PCSO tickets amounting to P997,373.60. The Commission on Audit (COA) initially flagged the issue, leading to an investigation by the Office of the Ombudsman. Villavert proposed a settlement plan to address his outstanding obligations, which was eventually approved by the PCSO Board of Directors. Despite this settlement, the Deputy Ombudsman-Visayas recommended Villavert’s dismissal for grave misconduct and dishonesty, a decision that was later approved by the Ombudsman. Villavert then sought recourse by filing a petition for review on certiorari with the Supreme Court, citing Section 27 of RA 6770 as the basis for his appeal. This is where the Supreme Court clarified existing rules of court and jurisprudence on appellate jurisdiction.

    However, the Supreme Court’s jurisdiction to hear the case was challenged by the landmark decision in Fabian v. Desierto. In Fabian, the Court declared Section 27 of RA 6770 unconstitutional insofar as it allowed direct appeals from the Ombudsman to the Supreme Court in administrative disciplinary cases. The Court reasoned that this provision violated Section 30, Article VI of the Constitution, which prohibits laws that increase the appellate jurisdiction of the Supreme Court without its advice and consent. The Supreme Court emphasized that Rule 45 of the 1997 Rules of Civil Procedure does not allow appeals from quasi-judicial agencies like the Ombudsman directly to the Supreme Court.

    The Supreme Court anchored its decision on the principle of separation of powers and the need to preserve the Court’s discretionary appellate jurisdiction. The Constitution grants the Supreme Court the power to define its jurisdiction, and Congress cannot expand this jurisdiction without the Court’s consent. Allowing direct appeals from the Ombudsman would unduly burden the Supreme Court and disrupt the established judicial hierarchy.

    The Court also considered the practical implications of its ruling. Requiring appeals to be filed with the Court of Appeals ensures a more thorough review of the Ombudsman’s decisions. The Court of Appeals can address factual and legal issues in greater detail, thereby streamlining the process for the Supreme Court should the case eventually reach it. This approach promotes judicial efficiency and allows the Supreme Court to focus on cases of significant national importance.

    The Supreme Court addressed the procedural implications of the Fabian ruling. The Court issued A.M. No. 99-2-02-SC, clarifying that any appeal filed with the Supreme Court after March 15, 1999, from a decision of the Ombudsman in administrative cases should be denied or dismissed outright. However, since Villavert’s petition was filed before this date, the Court ordered the case to be referred to the Court of Appeals for disposition under Rule 43 of the 1997 Rules of Civil Procedure. This demonstrated the Court’s commitment to applying the law fairly while respecting existing precedents.

    The decision has significant implications for public officials facing administrative charges before the Ombudsman. It clarifies the proper procedure for appealing adverse decisions, ensuring that they are reviewed by the appropriate appellate court. The ruling promotes consistency and predictability in the application of the law. It underscores the importance of adhering to constitutional principles and respecting the established judicial hierarchy. Public officials and their legal counsel must be aware of these jurisdictional requirements to ensure their appeals are properly filed and considered.

    The Supreme Court’s decision in Villavert, building on the precedent set in Fabian, serves to delineate the boundaries of appellate jurisdiction in administrative cases involving the Ombudsman. By reinforcing the role of the Court of Appeals as the primary appellate forum for these cases, the Supreme Court ensures that its own resources are reserved for matters of greater national significance and constitutional import. This approach contrasts with a system of direct appeals, which could potentially overwhelm the Supreme Court and undermine its ability to effectively manage its docket. Moreover, the clarified procedure promotes a more rigorous and systematic review of administrative decisions, safeguarding the rights of public officials while upholding the principles of accountability and transparency in government.

    FAQs

    What was the key issue in this case? The key issue was whether the Supreme Court had jurisdiction to directly hear appeals from decisions of the Office of the Ombudsman in administrative disciplinary cases, given Section 27 of RA 6770.
    What did the Supreme Court decide? The Supreme Court ruled that Section 27 of RA 6770, which allowed direct appeals to the Supreme Court, was unconstitutional, meaning appeals should first go to the Court of Appeals.
    Why was Section 27 of RA 6770 deemed unconstitutional? The Court found that it violated Section 30, Article VI of the Constitution, which states that no law shall increase the appellate jurisdiction of the Supreme Court without its advice and consent.
    What is the correct procedure for appealing an Ombudsman decision now? Appeals from decisions of the Office of the Ombudsman in administrative cases should be taken to the Court of Appeals under Rule 43 of the 1997 Rules of Civil Procedure.
    What happened to Villavert’s petition in this case? Because Villavert’s petition was filed before March 15, 1999, the Court ordered the case to be referred to the Court of Appeals for disposition under Rule 43.
    What was the basis for the administrative charges against Villavert? Villavert, a Sales & Promotion Supervisor at PCSO, faced charges related to unpaid PCSO tickets amounting to P997,373.60.
    What is the significance of the Fabian v. Desierto case? Fabian v. Desierto is the landmark case that established the unconstitutionality of direct appeals from the Ombudsman to the Supreme Court, setting the precedent for cases like Villavert.
    What practical impact does this ruling have on public officials? Public officials facing administrative charges need to ensure they appeal to the Court of Appeals first, following Rule 43, to properly challenge the Ombudsman’s decisions.

    The Villavert v. Desierto case stands as a crucial reminder of the importance of adhering to constitutional principles and respecting the established judicial hierarchy. The ruling ensures that appeals from the Ombudsman’s decisions are handled in a consistent and efficient manner, safeguarding the rights of public officials while upholding the integrity of the legal system.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Villavert v. Desierto, G.R. No. 133715, February 23, 2000

  • Ombudsman Decisions: Appealing Administrative Cases to the Right Court in the Philippines

    Filing an Ombudsman Appeal? Court of Appeals is the Correct Venue

    TLDR: Confused about where to appeal an administrative decision from the Ombudsman? This landmark Supreme Court case clarifies that appeals should be filed with the Court of Appeals, not directly with the Supreme Court. Understanding the correct court jurisdiction is crucial to ensure your appeal is properly heard and not dismissed on procedural grounds.

    G.R. NO. 124965, G.R. NO. 124932, G.R.NO. 124913. OCTOBER 29, 1998

    Introduction

    Imagine receiving a dismissal order from the Ombudsman after years of public service. Your career and reputation are on the line. Naturally, you want to appeal, seeking a higher court to review the decision. But where do you go? Do you directly approach the Supreme Court, the highest court in the land? This was precisely the predicament faced by several public officials in the late 1990s, highlighting a critical question: what is the proper judicial recourse for appealing administrative decisions from the Office of the Ombudsman?

    The consolidated cases of Namuhe v. Ombudsman, Tel-Equen v. Villa, and Mabunga v. Ombudsman, all decided on October 29, 1998, tackled this very issue. At the heart of these cases was the Supreme Court’s jurisdiction to directly review decisions of the Ombudsman imposing administrative sanctions. The petitioners, facing dismissal for alleged misconduct, sought direct review from the Supreme Court, unaware that a significant legal precedent was about to reshape the appellate process for Ombudsman cases.

    Legal Framework: Jurisdiction and Appeals from Quasi-Judicial Agencies

    To understand this case, we need to delve into the legal framework governing appeals in the Philippines, particularly concerning quasi-judicial agencies like the Ombudsman. The power of judicial review, the authority of courts to examine the actions of the other branches of government, is a cornerstone of our legal system. However, this power is not unlimited and is defined by the Constitution and relevant laws.

    Section 27 of Republic Act No. 6770, also known as the Ombudsman Act of 1989, initially stated that decisions of the Ombudsman could be appealed to the Supreme Court via a petition for review on certiorari under Rule 45 of the Rules of Court. Rule 45 is the procedural mechanism for appealing decisions from lower courts directly to the Supreme Court on questions of law.

    However, the Constitution, specifically Section 30, Article VI, states: “No law shall be passed increasing the appellate jurisdiction of the Supreme Court as provided in this Constitution without its advice and concurrence.” This provision essentially means that Congress cannot expand the Supreme Court’s jurisdiction without the Court’s consent.

    Furthermore, the 1997 Rules of Civil Procedure introduced Rule 43, which specifically governs appeals from quasi-judicial agencies to the Court of Appeals. A quasi-judicial agency is an administrative body that has powers and procedures resembling those of a court of law or judge, and the Ombudsman clearly falls under this category. Rule 43 provides a uniform procedure for appealing decisions from these agencies, streamlining the appellate process.

    The crucial question, therefore, became whether Section 27 of the Ombudsman Act unconstitutionally expanded the Supreme Court’s jurisdiction by allowing direct appeals, and whether Rule 43 should be the proper avenue for appealing Ombudsman decisions.

    Case Narrative: From Dismissal to Jurisdictional Question

    The petitioners in these consolidated cases were public officials from the Department of Public Works and Highways (DPWH). Romeo C. Namuhe and Romulo H. Mabunga were from the Ifugao Engineering District, while Jimmie F. Tel-Equen, Rolando D. Ramirez, and Rudy P. Antonio were from the Mountain Province Engineering District. They faced administrative complaints filed by the Ombudsman Task Force on Public Works and Highways for alleged irregularities related to public bidding for Bailey bridge components.

    The Ombudsman found them guilty of “dishonesty, falsification of public documents, misconduct and conduct prejudicial to the best interest of the service” and ordered their dismissal. Feeling aggrieved, the petitioners directly filed Petitions for Review on Certiorari with the Supreme Court under Rule 45, relying on Section 27 of the Ombudsman Act.

    However, the Supreme Court, even before delving into the merits of the petitioners’ claims, raised a fundamental issue: jurisdiction. Citing the then-recent landmark case of Fabian v. Desierto, the Court questioned whether it was indeed the proper forum to hear these appeals. In Fabian, the Supreme Court had already declared Section 27 of the Ombudsman Act unconstitutional, holding that it improperly expanded the Court’s appellate jurisdiction.

    The Court in Namuhe reiterated the Fabian ruling, stating: “In Fabian, the Court held that appeals from decisions of the Office of the Ombudsman in administrative disciplinary cases should be taken to the Court of Appeals under Rule 43 of the 1997 Rules of Civil Procedure.”

    The Supreme Court emphasized that Section 27 of RA 6770 violated the constitutional provision against increasing the Court’s appellate jurisdiction without its consent. Furthermore, the Court highlighted the purpose of Rule 43, which was to create a uniform appellate procedure for quasi-judicial agencies, including the Ombudsman. As the Court explained:

    “Appeals from judgments and final orders of quasi-judicial agencies are now required to be brought to the Court of Appeals on a verified petition for review, under the requirements and conditions in Rule 43 which was precisely formulated and adopted to provide for a uniform rule of appellate procedure for quasi-judicial agencies.”

    Ultimately, the Supreme Court, recognizing its lack of jurisdiction, did not dismiss the petitions outright. Instead, in the interest of justice and due process, it ordered the cases to be transferred to the Court of Appeals for proper adjudication. This transfer ensured that the petitioners’ right to appeal was preserved, albeit in the correct forum.

    Practical Takeaways: Navigating Appeals from the Ombudsman

    The Namuhe case, along with Fabian v. Desierto, provides crucial clarity on the appellate process for administrative decisions of the Ombudsman. It definitively establishes that the Court of Appeals, operating under Rule 43, is the proper venue for such appeals, not the Supreme Court via Rule 45.

    This ruling has significant practical implications for individuals and government employees facing adverse decisions from the Ombudsman. Understanding the correct appellate procedure is essential to avoid procedural errors that could lead to the dismissal of an appeal, regardless of its merits.

    For legal practitioners, this case serves as a constant reminder to always verify the proper jurisdiction and procedure when handling appeals from quasi-judicial agencies. Filing an appeal in the wrong court can result in wasted time, resources, and potentially, the loss of the right to appeal altogether.

    Key Lessons:

    • Court of Appeals is the Correct Venue: Appeals from administrative disciplinary decisions of the Ombudsman must be filed with the Court of Appeals under Rule 43 of the Rules of Court.
    • Section 27 of RA 6770 is Unconstitutional: Section 27 of the Ombudsman Act, which allowed direct appeals to the Supreme Court, has been declared unconstitutional.
    • Importance of Procedural Rules: Adhering to the correct rules of procedure, particularly regarding jurisdiction and venue, is critical in appellate practice.
    • Seek Legal Counsel: Navigating the complexities of administrative law and appellate procedure can be challenging. Consulting with a lawyer is highly recommended when facing an Ombudsman decision.

    Frequently Asked Questions (FAQs)

    Q: Where do I appeal an administrative decision from the Ombudsman?

    A: You should file your appeal with the Court of Appeals under Rule 43 of the Rules of Court.

    Q: What is Rule 43 of the Rules of Court?

    A: Rule 43 provides the rules and procedures for appealing decisions from quasi-judicial agencies to the Court of Appeals. It standardizes the appellate process for these types of cases.

    Q: What is a quasi-judicial agency? Is the Ombudsman considered one?

    A: A quasi-judicial agency is an administrative body that has powers and procedures similar to a court, including the power to investigate facts, hold hearings, and make decisions affecting the rights of individuals. The Ombudsman is considered a quasi-judicial agency.

    Q: What was the significance of the Fabian v. Desierto case mentioned in Namuhe v. Ombudsman?

    A: Fabian v. Desierto was the landmark Supreme Court case that declared Section 27 of the Ombudsman Act unconstitutional. It established the precedent that appeals from Ombudsman administrative decisions should go to the Court of Appeals.

    Q: What happens if I mistakenly file my Ombudsman appeal directly with the Supreme Court?

    A: The Supreme Court will likely dismiss your petition for lack of jurisdiction. However, as seen in Namuhe, the Court may, in the interest of justice, transfer the case to the Court of Appeals. It’s always best to file in the correct court from the outset.

    Q: Why is it important to appeal to the correct court?

    A: Jurisdiction is fundamental. If you file your case in the wrong court, that court has no legal authority to hear your case. This can lead to dismissal of your case on procedural grounds, regardless of the merits of your arguments.

    Q: Does this ruling apply to all types of Ombudsman decisions?

    A: This ruling specifically applies to appeals from administrative disciplinary decisions of the Ombudsman. Appeals in criminal cases handled by the Ombudsman may have different procedures.

    Q: If the Supreme Court transferred the cases to the Court of Appeals, did the petitioners eventually win their appeals?

    A: This decision only addressed the issue of jurisdiction. The Supreme Court did not rule on the merits of the petitioners’ cases. The Court of Appeals would then be responsible for reviewing the Ombudsman’s decision on its substantive merits.

    Q: Has the law changed since this case was decided in 1998?

    A: The principle established in Fabian and reaffirmed in Namuhe remains good law. Appeals from administrative decisions of the Ombudsman are still properly filed with the Court of Appeals under Rule 43.

    Q: Where can I find the full text of Rule 43 of the Rules of Court?

    A: You can find the full text of the Rules of Court, including Rule 43, on the Supreme Court of the Philippines website or through legal databases and publications.

    ASG Law specializes in Administrative Law and Civil Litigation. Contact us or email hello@asglawpartners.com to schedule a consultation.