In the SALVADOR vs. MAPA case, the Ombudsman initially dismissed the Committee's complaint on the grounds that the offenses had prescribed and that the use of Administrative Order No. 13 and Memorandum Order No. 61 would render them as ex post facto laws, which are prohibited by the Constitution. This dismissal was challenged in court, where the Supreme Court overturned the Ombudsman's decision, ruling that the orders were not penal in nature and therefore not ex post facto. The role of the Ombudsman as an evaluating authority was challenged when the Supreme Court directed it to evaluate the merits of the complaint against the respondents, thereby requiring it to address the substantive issues of the case without dismissing it on the aforementioned basis .

The Ombudsman dismissed the original complaint regarding behest loans because it determined that the offenses had already prescribed, meaning they were no longer actionable due to the expiration of the relevant statute of limitations. Furthermore, the Ombudsman argued that if Administrative Order No. 13 and Memorandum Order No. 61 were to serve as the basis for charging the respondents, they would function as ex post facto laws, which are unconstitutional. This argument was based on the belief that the orders applied retroactive penalties to actions that were not criminal when originally conducted .

The constitutional prohibition against ex post facto laws serves as protection by ensuring that individuals are not retroactively subjected to criminal laws that did not exist at the time of their actions. This prevents the legislative and executive branches from enacting laws that would penalize previously innocent behavior or increase the severity of punishments after an act has been committed. It also ensures that legal standards needed to convict are not diminished retroactively. This protection contributes to fair legal proceedings by maintaining consistent legal parameters, thereby upholding fundamental justice and preventing arbitrary state action .

The Supreme Court rejected the characterization of Administrative Order No. 13 and Memorandum Order No. 61 as ex post facto laws because these orders did not meet the criteria of penal laws according to legal doctrine. Penal laws are retrospective when they criminalize innocent actions post facto, aggravate past offenses, change punishment, or alter legal protections like amnesty, which was not the case here. Instead, Administrative Order No. 13 established a fact-finding committee without imposing penalties, and Memorandum Order No. 61 simply provided criteria for identifying behest loans. Since they did not penalize past conduct or alter legal consequences established by prior law, the orders could not be considered ex post facto .

The Supreme Court's directive to the Office of the Ombudsman to conduct with dispatch an evaluation of the merits of the complaint emphasized the need for substantive examination over procedural dismissal. By setting aside the Ombudsman's decision, the Court underscored the importance of assessing allegations of graft and corruption on their factual and legal merits rather than dismissing them on procedural technicalities. This directive signifies the Court's commitment to combating corruption by ensuring accountability through thorough investigations, opening a path for potentially more comprehensive judicial scrutiny of similar cases in the future .

In the case of SALVADOR vs. MAPA, the legal concept of an ex post facto law was applied to determine whether Administrative Order No. 13 and Memorandum Order No. 61 were proscribed by the Constitution. An ex post facto law retrospectively changes the legal consequences of actions that were committed before the enactment of the law, making an action criminal that was innocent when done, or altering the punishment after the fact, among other things. However, the Supreme Court found that these orders were not penal in nature. Administrative Order No. 13 created a fact-finding committee and outlined its functions without imposing any penalties, while Memorandum Order No. 61 provided criteria for determining behest loans. Since neither order established new penalties or redefined crimes, they did not meet the criteria for ex post facto laws as defined by legal doctrine .

The Supreme Court's ruling in the SALVADOR vs. MAPA case establishes a significant precedent that administrative orders, which establish procedural frameworks or guidelines rather than punishments, are not considered ex post facto laws. This means that future administrative orders aimed at investigating behaviors such as financial misconduct will not be invalidated under the claim that they impose retrospective penalties, provided they do not introduce or redefine punishments. The decision upholds the ability of the government to form committees and investigate past financial misconduct without such actions being dismissed as retrospective legislation .

The criteria for ex post facto laws maintain the integrity of legal systems by ensuring that laws do not retroactively criminalize actions, increase the severity of crimes, alter the legal rules of evidence, or reduce protections afforded by previous statutes. This protection upholds fundamental fairness, preventing individuals from being surprised by retrospective penal actions. It establishes a consistent legal environment where individuals and entities can rely on the law as it existed at the time of their actions. This consistency and predictability reinforce trust in the legal system, deter arbitrary government use of power, and protect constitutional rights, thereby bolstering the overall integrity of judicial and legislative processes .

The doctrine of ex post facto laws influences legislative and executive action by limiting their power to enact retroactive penalties, thus safeguarding against arbitrary and oppressive legal actions. It prevents the government from criminalizing conduct after the fact or altering punishments for actions that were not criminal at the time of commission. This ensures stability in the legal system and protects individual rights by requiring that all laws imposing sanctions must be prospective in nature. Consequently, it requires lawmakers and the executive to carefully draft legislation that respects these temporal limits and to apply new regulations only to future actions, reinforcing the principle of legal predictability and fairness .

The SALVADOR vs. MAPA case sets a precedent by clarifying that administrative orders, which establish investigative bodies and provide procedural guidelines without imposing penalties, do not constitute ex post facto laws. This case suggests that administrative orders can be used to guide investigations into past conduct as long as they do not retroactively redefine legal obligations or penalties. Therefore, administrative orders are interpreted as investigatory and procedural tools rather than punitive regulations, provided they do not alter established legal consequences or impose retrospective sanctions, thereby affirming their legality in pursuing investigations in similar contexts .