G.R. No. 205659 . March 09, 2022
PSI DARWIN D. VALDERAS, PETITIONER, VS. VILMA O. SULSE, RESPONDENT.

FACTS

The case arose from an incident on May 9, 2006, at the Taft Police Station, Eastern Samar, where respondent Vilma O. Sulse, former Secretary of the Sangguniang Bayan, alleged she was mauled by Mayor Francisco Adalim. Petitioner PSI Darwin D. Valderas was the Chief of Police. Respondent claimed that while she was reporting a ransacking of her office to SPO1 Neceas Lusico, Mayor Adalim arrived and struck her head several times and banged it against a wall, witnessed by several police officers who did not intervene. When petitioner arrived, respondent asked for the mauling to be recorded in the police blotter, but petitioner allegedly denied her request. Respondent was detained and later released after surrendering two envelopes. A medical examination 43 days later indicated injuries that would incapacitate her for three to six days. Petitioner countered that he arrived after the alleged incident, that an entry was made in the police blotter regarding a dispute over office records (but not the mauling), and that respondent never requested her version be recorded. The Ombudsman initially found petitioner and other officers guilty of Simple Neglect of Duty and imposed a two-month suspension. Upon reconsideration, the Ombudsman exonerated the other officers, finding respondent failed to substantiate the assault claim, but maintained petitioner’s liability for failing to record the alleged mauling, reducing his penalty to a one-month suspension. The Court of Appeals affirmed this decision.

ISSUE

Whether or not the Court of Appeals erred in affirming the Ombudsman’s finding of Simple Neglect of Duty on the part of petitioner.

RULING

The Supreme Court granted the petition and reversed the rulings of the Court of Appeals and the Ombudsman. The Court held that petitioner could not be held liable for Simple Neglect of Duty. The Ombudsman itself had exonerated the other officers by finding that respondent failed to prove the mauling incident occurred and that no witnesses saw it. Consequently, there was no duty on the part of petitioner to record a non-existent mauling in the police blotter. The police blotter entries (Nos. 2081 and 2082) properly recorded the actual incident that transpired—a confrontation between respondent, the Mayor, and the Vice Mayor regarding missing office records and the subsequent turnover of documents. Simple Neglect of Duty is defined as the failure to give proper attention to a task, signifying a disregard of duty due to carelessness or indifference. Since the factual basis for the alleged duty (to record an assault) was explicitly rejected by the Ombudsman, no neglect could be attributed to petitioner for not performing that duty. The findings of the CA were based on speculation in affirming liability despite the absence of a proven factual duty. Thus, petitioner was absolved of administrative liability.