GR 139943; (January, 2001) (Digest)
G.R. No. 139943 January 18, 2001
MANUEL MIRALLES, petitioner, vs. HON. SERGIO F. GO, Chairman of the National Police Commission; and PABLO S. VILLANUEVA, respondents.
FACTS
Petitioner Manuel Miralles, a police officer, was administratively charged with Grave Misconduct for the fatal shooting of Patrolman Nilo Resurreccion and Ernesto Merculio on October 19, 1977. After investigation, the NAPOLCOM Hearing Officer found him guilty and recommended dismissal. The NAPOLCOM Adjudication Board affirmed this decision on September 10, 1980. Petitioner’s appeal to the NAPOLCOM Special Appellate Committee (SAC) was initially dismissed for abandonment but was later reinstated. Ultimately, the SAC affirmed the dismissal in a Resolution dated October 30, 1989. Petitioner received a copy of this resolution only on November 5, 1996, after which he filed a petition directly with the Court of Appeals.
The Court of Appeals dismissed the petition. It initially ruled the recourse was premature, as under the then-governing RA 6975, the SAC decision should have been appealed first to the Civil Service Commission. Nevertheless, the CA proceeded to rule on the merits, upholding the factual findings of the NAPOLCOM and finding the evidence, including an eyewitness account, sufficient to establish petitioner’s guilt. The CA rejected petitioner’s claim of self-defense for lack of substantiation.
ISSUE
The primary issues are: (1) the propriety of petitioner’s direct recourse to the Court of Appeals; and (2) the sufficiency of the evidence to sustain his dismissal for Grave Misconduct.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. On the procedural issue, the Court held that while the CA correctly noted the procedural lapse, it did not err in ultimately taking cognizance of the case and deciding it on the merits. The Court emphasized that rules of procedure should not be applied rigidly to defeat substantive justice, especially given the delay in petitioner’s receipt of the SAC resolution.
On the substantive issue, the Court upheld the factual findings of the NAPOLCOM as affirmed by the CA. It reiterated the settled doctrine that factual findings of administrative agencies, when supported by substantial evidence and affirmed by the CA, are binding and conclusive upon the Supreme Court. The Court found that the NAPOLCOM’s conclusion was amply supported by the evidence on record, particularly the eyewitness testimony of Alejandro Lamsen who positively identified petitioner as the shooter. The various documentary evidence, including sworn statements, medico-legal reports, and ballistic findings, constituted substantial evidence supporting the administrative charge. Petitioner’s bare allegation of self-defense, unsupported by convincing evidence, was rightly rejected. Consequently, the penalty of dismissal from the service was upheld as commensurate to the offense of Grave Misconduct.