GR 123048; (August, 2000) (Digest)
G.R. No. 123048 ; August 8, 2000
YOLANDA FLORALDE, NIDA VELASCO and NORMELITA ALAMBRA, petitioners, vs. COURT OF APPEALS, CIVIL SERVICE COMMISSION and PAULINO W. RESMA, respondents.
FACTS
Petitioners Yolanda Floralde, Nida Velasco, and Normelita Alambra, rank-and-file employees of the Agricultural Training Institute (ATI) under the Department of Agriculture, filed separate complaints for grave misconduct (sexual harassment) against their superior, respondent Paulino W. Resma, the Division Chief and Officer-in-Charge of ATI. The complaints, filed directly with the Civil Service Commission (CSC) on April 23, 1994, detailed specific incidents of unwelcome physical advances and lewd remarks by Resma. The CSC gave due course to the complaints, formally charged Resma, placed him under preventive suspension, and conducted a formal investigation.
During the investigation, petitioners affirmed their affidavits under oath, providing categorical narrations of the harassment incidents and undergoing cross-examination. They testified that Resma, who signed their daily time records, made amorous advances, touched intimate body parts, and made sexually suggestive comments, leveraging his supervisory power. Resma denied all accusations, presented an alibi, and claimed the complaints were fabricated and instigated by a rival for promotion. The CSC, convinced by petitioners’ positive testimonies, found Resma guilty and dismissed him from service. On appeal, the Court of Appeals reversed the CSC, prompting this petition.
ISSUE
Whether the Court of Appeals erred in reversing the CSC’s resolutions on the ground that the finding of guilt was not supported by substantial evidence.
RULING
Yes, the Court of Appeals erred. The Supreme Court reinstated the CSC’s decision, finding Resma guilty of grave misconduct. In administrative proceedings, the quantum of proof required is substantial evidence, or such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. The CSC’s finding was amply supported by the detailed, consistent, and positive testimonies of the three petitioners, who were subjected to cross-examination. Their accounts demonstrated a pattern of abuse of power by a superior over subordinates whose employment he could influence.
The Court emphasized that sexual harassment is about the abuse of power, not merely sexual desire. Resma’s defense of alibi and alleged fabrication by a rival was deemed unconvincing. The Court noted that filing such grave charges is not trivial and subjects complainants to public scrutiny, making collusion improbable. The CSC, as the specialized administrative body, is in the best position to assess witness credibility and evidence weight. Its factual findings, supported by substantial evidence, command respect and finality. Thus, the appellate court overstepped by re-evaluating the evidence and substituting its own judgment. The penalty of dismissal for grave misconduct was affirmed.