EBARLE VS. SUCALDITO


FACTS
The petitioner, Bienvenido Ebarle, is the then provincial Governor of Zamboanga del Sur and a candidate for election for the same position. He has been charged for the violation of certain provisions of the Anti-Graft and Corrupt Practices Act. RA No. 3019, and various provisions of the Revised Penal Code by the herein respondents. The petitioner claims on his defense that the respondents failed to comply with the provisions of EO N.O. 264, “Outlining the Procedure by Which Complainants Charging Government Officials and Employees with Commission of Irregularities Should Be Guided”, prior to their criminal recourses.

ISSUE
Whether or not the provisions of EO No. 264 are applicable to the respondents.


HELD
No, EO No. 264 has exclusive application to administrative, not criminal complaints. The title speaks of “commission of irregularities”. There is no mention, not even by implication, of criminal offenses, that is to say, crimes. Even though crimes amount to irregularities, the aforesaid Order could have very well referred to the more specific term, had it intended to make itself applicable thereto.

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