GR 140128; (June, 2001) (Digest)
G.R. No. 140128; June 6, 2001
ARNOLD P. MOLLANEDA, petitioner, vs. LEONIDA C. UMACOB, respondent.
FACTS
The case stemmed from an affidavit-complaint for sexual harassment filed by respondent Leonida Umacob against petitioner Arnold Mollaneda, a Schools Division Superintendent, with the Civil Service Commission – Regional Office XI (CSC-RO XI) in September 1994. Respondent alleged that on September 7, 1994, inside an office at the Division Office Building, petitioner, after discussing her request for transfer, suddenly hugged and embraced her, kissed her nose and lips in a torrid manner, and mashed her left breast, warning her not to tell anybody. She reported the incident to the police the following day. Petitioner denied the allegations, pointing out material contradictions in respondent’s version and claiming the interview was brief and no sexual harassment occurred, with witnesses attesting to this. The Department of Education, Culture and Sports (DECS) investigating committee recommended dropping the case for lack of merit. However, the CSC-RO XI found a prima facie case and charged petitioner with grave misconduct, oppression, abuse of authority, and conduct prejudicial to the best interest of the service. The Civil Service Commission (CSC), after a formal hearing, issued Resolution No. 973277 finding petitioner guilty of grave misconduct and conduct grossly prejudicial to the best interest of the service, meting the penalty of dismissal. The Court of Appeals affirmed the CSC resolution in toto. Petitioner filed a petition for review, raising issues regarding the appreciation of evidence and the administrative procedure.
ISSUE
The core issue is whether the Civil Service Commission and the Court of Appeals erred in finding petitioner guilty of grave misconduct and conduct grossly prejudicial to the best interest of the service based on the evidence presented.
RULING
The Supreme Court DENIED the petition and AFFIRMED the assailed Decision and Resolution of the Court of Appeals. The Court held that the findings of fact of administrative bodies, such as the Civil Service Commission, are accorded respect and finality when supported by substantial evidence, as in this case. The Court found no reason to deviate from the consistent findings of the CSC and the Court of Appeals, which found the complainant’s testimony credible and sufficient to establish petitioner’s guilt. The Court emphasized that in administrative proceedings, substantial evidence is sufficient, and the complainant’s positive testimony, corroborated by her immediate reporting of the incident, carried more weight than petitioner’s denial and the affidavits of his witnesses. The Court also ruled that the investigating officer’s act of summarizing witness testimonies for the Commission did not violate petitioner’s right to due process, as the officer who decides must consider the evidence, but this does not preclude the use of assistants to sift and analyze evidence. The penalty of dismissal was deemed appropriate for the grave offense committed.