CASE DIGEST
PROVINCE OF BATAAN V.
CASIMIRO
G.R. No. 197510-11, April
18, 2022
SECOND DIVISION, HERNANDO
J.
Certiorari,
Ombudsman, Mootness, Hierarchy of Courts
DOCTRINE: Mootness of the case due to subsequent
events, particularly the advancement of criminal trials and administrative
proceedings in the Sandiganbayan, leads to the issues raised becoming
irrelevant and non-justiciable.
In this case, Provincial Agriculturist
Imelda D. Inieto requested a patrol boat equipped with a 6-cylinder gas engine
to aid the Bataan Provincial Anti-Illegal Fishing Task Force. A series of
irregularities occurred during the procurement process, involving alterations
in specifications, lack of competitive bidding, and payment for a patrol boat
that was not delivered on time. The Bids and Awards Committee (BAC) recommended
a limited source bidding and awarded the contract to Ernesto R. Asistin Jr. for
a 4-cylinder gas engine patrol boat instead of the requested 6-cylinder one.
The Ombudsman found various public officials and individuals guilty of grave
misconduct, dishonesty, and falsification of documents in the procurement
process. Subsequently, criminal and administrative cases were filed, and the
case reached the Court of Appeals and later the Supreme Court through petitions
and motions, raising questions about the legality of the proceedings and the
involvement of various individuals in the irregularities.
Whether or not the case should be dismissed due to
mootness and failing to adhere to the hierarchy of courts?
NO. The consolidated petitions involve legal
challenges related to criminal and administrative cases against public
officials accused of wrongdoing. In a complex sequence of events, the involved
officials were charged with offenses, such as violation of RA 3019 and
falsification of public documents. The issues spanned issues of jurisdiction,
abuse of discretion, proper procedures, and the existence of probable cause.
Over time, certain accused were dropped from cases, trials commenced, and
appeals were made.
The court also emphasized the importance of adhering to the hierarchy of courts, highlighting that administrative cases should be appealed through appropriate channels, particularly through Rule 43 petitions filed with the Court of Appeals. Consequently, the court dismissed the petitions, underscoring the principle of mootness and the significance of respecting the hierarchy of courts.
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