The Ombudsman possesses prosecutorial powers and exercises supervision and control over the Office of the Special Prosecutor (OSP) as constitutionally sanctioned by Congress through Republic Act No. 6770; consequently, the Ombudsman has the authority to approve, disapprove, or overturn any resolution issued by the OSP.

The case originated from a complaint-affidavit filed by the Fact-Finding and Intelligence Bureau of the Office of the Ombudsman against then Congressman Carmelo F. Lazatin and his co-petitioners. The complaint alleged irregularities in the use of Lazatin's Countrywide Development Fund (CDF) for 1996, where he was accused of being both the proponent and implementer of projects, signing disbursement vouchers, and receiving checks as claimant, effectively converting public funds into cash.

• On July 22, 1998, a complaint was filed with the Ombudsman against Congressman Carmelo F. Lazatin, Marino A. Morales, Angelito A. Pelayo, and Teodoro L. David for Illegal Use of Public Funds and violation of R.A. 3019.
• The complaint alleged that Lazatin, in using his 1996 Countrywide Development Fund (CDF), acted as both proponent and implementer of projects, signed vouchers as Disbursing Officer, and received eighteen checks amounting to P4,868,277.08 as claimant.
• Following a preliminary investigation, the Ombudsman approved the filing of fourteen counts each of Malversation of Public Funds and violation of Section 3(e) of R.A. 3019 against the petitioners before the Sandiganbayan.
• The Sandiganbayan granted the petitioners' motion for reinvestigation, and the Office of the Special Prosecutor (OSP) subsequently issued a resolution recommending the dismissal of the cases for lack of evidence.
• On October 27, 2000, the Ombudsman disapproved the OSP's recommendation and ordered the prosecution to proceed with the trial, prompting the petitioners to file a petition for certiorari with the Supreme Court.

• The Ombudsman acted with grave abuse of discretion or in excess of his jurisdiction by overturning the OSP's resolution recommending dismissal.
• Under the 1987 Constitution, the Ombudsman's power is limited to investigating and recommending the filing of cases, not prosecuting them.
• The OSP (formerly Tanodbayan) is a separate and distinct entity from the Office of the Ombudsman, and therefore, the Ombudsman has no authority or control over it.
• Republic Act No. 6770 (The Ombudsman Act of 1989), which placed the OSP under the Ombudsman, is unconstitutional.
• The Ombudsman's decision was based on misapprehension of facts, as the checks issued to Lazatin were merely reimbursements for personal funds he advanced for projects aiding Pinatubo victims.

• The Ombudsman's actions were in accordance with the powers granted by Republic Act No. 6770, which is a constitutional exercise of Congress's power to legislate.
• The Ombudsman possesses the power of supervision and control over the OSP, which is an organic component of the Office of the Ombudsman.
• The disapproval of the OSP's resolution was a valid exercise of the Ombudsman's prosecutorial discretion and authority.
• The issue of whether there is sufficient evidence for probable cause is a matter of judgment, not jurisdiction, and is not correctible by a writ of certiorari.

• Procedural Issues:
  • Whether a petition for certiorari is the proper remedy to challenge the Ombudsman's finding of probable cause, which petitioners allege is based on a misapprehension of facts.
• Substantive Issues:
  • Whether Republic Act No. 6770, which grants prosecutorial powers to the Ombudsman and places the Office of the Special Prosecutor under its supervision and control, is unconstitutional.
  • Whether the Ombudsman has the authority to disapprove a resolution of the Office of the Special Prosecutor recommending the dismissal of criminal cases.
  • Whether the doctrine of stare decisis should be set aside to re-examine the constitutionality of R.A. No. 6770.

• Procedural:
  • The petition for certiorari is dismissed as it is not the proper remedy. Certiorari is intended to correct errors of jurisdiction, not errors of judgment. The determination of probable cause is a function of the Ombudsman, and any error in the evaluation of evidence is an error of judgment that cannot be remedied by certiorari.
• Substantive:
  • Yes, Republic Act No. 6770 is constitutional. The 1987 Constitution, in Article XI, Section 13(8), explicitly authorizes Congress to grant the Ombudsman "such other functions or duties as may be provided by law," which includes prosecutorial powers and the power to place the OSP under its supervision.
  • Yes, the Ombudsman has the authority to disapprove the OSP's resolution. Since the OSP is merely a component of the Office of the Ombudsman under R.A. 6770, it acts under the supervision and control of the Ombudsman, who can therefore approve or disapprove its actions and recommendations.
  • No, the doctrine of stare decisis will not be set aside. The petitioners failed to present any strong or compelling reason to abandon the long-standing and repeatedly affirmed jurisprudence upholding the constitutionality of R.A. No. 6770 and the Ombudsman's powers thereunder.

• Stare Decisis et non quieta movere — This doctrine, which means "to adhere to precedents and not to unsettle things which are established," requires courts to follow the rule established in a decision of the Supreme Court. The Court invoked this doctrine to refuse to revisit the settled issue of the constitutionality of R.A. No. 6770, as petitioners failed to provide compelling reasons to abandon established precedent.
• Error of Jurisdiction vs. Error of Judgment — An error of jurisdiction occurs when a court acts without or in excess of its jurisdiction, correctible by certiorari. An error of judgment is a mistake in the application of law or appreciation of evidence within the court's jurisdiction, which is not correctible by certiorari. The Court applied this to rule that the Ombudsman's finding of probable cause, even if allegedly wrong, was an error of judgment and thus not reviewable via certiorari.
• Ombudsman's Supervision and Control over the OSP — This principle, established by R.A. No. 6770 and upheld by jurisprudence, dictates that the Office of the Special Prosecutor is an organic component of the Office of the Ombudsman and acts under the latter's authority. The Court used this to validate the Ombudsman's act of disapproving the OSP's resolution.
• Ombudsman's Prosecutorial Discretion — The Court recognizes the wide latitude of the Ombudsman in exercising its investigatory and prosecutory powers and adheres to a policy of non-interference with such powers, provided they are supported by substantial evidence and not tainted by grave abuse of discretion. This was invoked to uphold the Ombudsman's decision to proceed with the prosecution.

• "The doctrine of stare decisis enjoins adherence to judicial precedents. It requires courts in a country to follow the rule established in a decision of the Supreme Court thereof. That decision becomes a judicial precedent to be followed in subsequent cases by all courts in the land. The doctrine of stare decisis is based on the principle that once a question of law has been examined and decided, it should be deemed settled and closed to further argument."
• "In certiorari proceedings, judicial review does not go as far as to examine and assess the evidence of the parties and to weigh the probative value thereof. It does not include an inquiry as to the correctness of the evaluation of evidence. Any error committed in the evaluation of evidence is merely an error of judgment that cannot be remedied by certiorari."

• Acop v. Office of the Ombudsman — Cited as the controlling precedent that fully dissected and settled the issue of the constitutionality of R.A. No. 6770, specifically its provisions granting prosecutorial powers to the Ombudsman and placing the OSP under its supervision.
• Camanag v. Guerrero — Referenced as a case that reiterated the ruling in Acop regarding the constitutionality of the Ombudsman's powers.
• Office of the Ombudsman v. Valera — Cited to support the ruling that the OSP is merely a component of the Office of the Ombudsman and may only act under its supervision, control, and authority.
• Perez v. Sandiganbayan — Referenced to show that the Ombudsman's power to prosecute, as established in Acop, includes the power to authorize the filing of informations.
• Fermin v. People — Cited for its clear definition and explanation of the doctrine of stare decisis.
• First Corporation v. Former Sixth Division of the Court of Appeals — Cited to emphasize the legal principle that certiorari is an extraordinary remedy for errors of jurisdiction, not for errors of judgment like the appreciation of evidence.

• 1987 Constitution, Article XI, Section 13(8) — This provision grants the Office of the Ombudsman the power to "exercise such other functions or duties as may be provided by law," which the Court interpreted as the constitutional basis for Congress to enact R.A. No. 6770 and expand the Ombudsman's powers.
• Republic Act No. 6770 (The Ombudsman Act of 1989) — This is the central statute challenged by the petitioners. The Court upheld its constitutionality, particularly its provisions granting prosecutorial powers to the Ombudsman and making the OSP an organic component of its office.
• Civil Code, Article 8 — Cited as the statutory basis for the doctrine of stare decisis, as it provides that judicial decisions applying or interpreting the laws or the Constitution shall form part of the legal system of the Philippines.
• Rules of Court, Rule 65 — This rule governs the petition for certiorari, the remedy availed of by the petitioners, which the Court found to be improper for challenging an alleged error of judgment.