G.R. No. 230355 , March 18, 2021
Sonia O. Mahinay, Petitioner, vs. Court of Appeals and Alma J. Genotiva, Respondents.

FACTS

Private respondent Alma J. Genotiva filed a complaint before the Civil Service Commission Regional Office No. VIII (CSCRO VIII) against several employees of the Professional Regulation Commission (PRC) Tacloban Office, including petitioner Sonia O. Mahinay, for conflict of interest, grave abuse of authority, dishonesty, and violation of graft and corrupt practices and the Anti-Red Tape Act. The complaint alleged that the employees, who were also officers/members of the PRC Employees Multi-Purpose Cooperative (PREMPC), took PRC property (forms, documentary stamps, window envelopes) and sold them for personal gain through the cooperative. The CSCRO VIII found a prima facie case and formally charged Mahinay with Grave Misconduct for leaving her post and taking/selling PRC forms on specified dates in 2008 and 2009. Initially, the CSCRO VIII found her guilty of Conduct Prejudicial to the Best Interest of the Service, imposing a six-month and one-day suspension, later downgraded to Simple Misconduct with a three-month and one-day suspension. On appeal, the Civil Service Commission (CSC) found her guilty of Grave Misconduct and Conduct Prejudicial to the Best Interest of the Service and imposed the penalty of dismissal. Mahinay filed a petition for review before the Court of Appeals (CA). The CA dismissed her petition for failure to attach several documents (Exhibits “6” and “9”) in violation of Section 6(c), Rule 43 of the Revised Rules of Court, despite her partial compliance and motion for extension. Mahinay filed a Petition for Certiorari under Rule 65 before the Supreme Court. She also manifested that a co-respondent, Maria Evelyn D. Larraga, charged in the same formal charge, was absolved by the CA in a separate case.

ISSUE

1. Whether the CA committed grave abuse of discretion in dismissing the petition for review on procedural grounds.
2. Whether petitioner is liable for committing Grave Misconduct.

RULING

The Supreme Court GRANTED the petition. On the procedural issue, the Court noted that Mahinay availed of the wrong remedy (Rule 65 instead of Rule 45) but decided to relax procedural rules in the interest of substantial justice. The Court found that the CA’s dismissal on technical grounds was too harsh, especially since the missing documents were not vital, the OSG did not raise their absence, and Mahinay attempted to secure them. On the substantive issue, the Court set aside the CSC’s decision and absolved Mahinay of administrative liability. The Court found that the evidence against her, primarily based on the complainant’s allegations, was insufficient to establish guilt by substantial evidence. The charges lacked specific details and corroboration. Crucially, the Court gave weight to the fact that in a separate but related case involving the same complainant, evidence, and charges, the CA had absolved co-respondent Larraga. This determination, while independent, served as an added reason to warrant reversal, as both were similarly situated. Thus, the assailed CA Resolutions and the CSC Decision and Resolution were set aside.