G.R. No. 149022 ; April 8, 2003
Carmencita D. Coronel, petitioner, vs. Hon. Aniano A. Desierto, as Ombudsman, and Pedro Sausal, Jr., respondents.

FACTS

Petitioner Carmencita D. Coronel, a Senior Accounting Processor and Officer-In-Charge of the Linamon Water District, sought reimbursement for P1,213.00 spent on a luncheon meeting for officers from various water districts and LWUA advisors. She submitted Cash Invoice No. 0736 from Marvilla’s Store as proof. Pedro Sausal, Jr., subsequently appointed as General Manager, filed an administrative complaint for dishonesty with the Office of the Ombudsman. He alleged that Coronel falsified the receipt by altering the amount from P213.00 to P1,213.00, submitting a photocopy of the store’s duplicate invoice showing the lower amount as evidence.
The Ombudsman found Coronel guilty of dishonesty, ordering her dismissal with forfeiture of benefits and perpetual disqualification from government service. The ruling was based on the discrepancy between the submitted receipt and the photocopied duplicate, concluding that Coronel, who had possession of the original, likely added the numeral “1” to inflate the amount. Coronel filed a motion for reconsideration, attaching new evidence including an affidavit from the store owner affirming the P1,213.00 charge and affidavits from meeting attendees corroborating the expense.

ISSUE

Whether the Supreme Court should give due course to the petition for certiorari despite procedural defects, to prevent a grave miscarriage of justice.

RULING

Yes. The Supreme Court relaxed procedural rules to refer the case to the Court of Appeals for merits adjudication. While Coronel’s petition for certiorari under Rule 65 was improper—as a judgment from the Ombudsman in an administrative case is appealable via a petition for review under Rule 43 to the Court of Appeals—the Court suspended strict application of its procedural circular. This exceptional action was justified by the strong showing of a potential grave miscarriage of justice.
The Ombudsman’s decision carried the severe penalty of dismissal and perpetual disqualification, effectively ending Coronel’s government career and livelihood. Crucially, her motion for reconsideration before the Ombudsman, which included newly submitted affidavits from the store proprietor and multiple attendees directly contesting the falsification allegation, was initially granted by the Graft Investigation Officer but was later disapproved. This created a substantial doubt regarding the factual basis of the charge. The Court emphasized that rules of procedure are tools to promote justice, not to frustrate it. Where a rigid application would result in irreparable damage and deny a hearing on potentially exculpatory evidence, the Court may exercise its discretion to relax the rules in the interest of substantial justice. Thus, the petition was treated as a petition for review under Rule 43 and referred to the Court of Appeals.