GR 149999; (August, 2005) (Digest)
G.R. No. 149999 . August 12, 2005
THE NATIONAL APPELLATE BOARD (NAB) OF THE NATIONAL POLICE COMMISSION (NAPOLCOM), Petitioner, vs. P/INSP. JOHN A. MAMAUAG, SPO2 EUGENE ALMARIO, SPO4 ERLINDA GARCIA and SPO1 VIVIAN FELIPE, Respondents.
FACTS
On March 2, 1995, two minors, later classified as mental retardates, were found wandering and brought to a police station. They alleged maltreatment by Judge Adoracion Angeles. Police respondents Mamauag, Almario, Garcia, and Felipe were involved in recording the complaint, conducting an initial investigation, and escorting the minors to the Department of Social Welfare. Judge Angeles filed an administrative complaint for Grave Misconduct against them, alleging irregular handling of the complaint and a related theft incident. The initial investigation by the CPDC-ILAD recommended dismissal of the charges, which the District Director approved.
Judge Angeles moved for reinvestigation. The PNP Chief initially found some respondents guilty of neglect, exonerating Garcia and Felipe, but later, upon reconsideration, ordered the dismissal from service of all four police respondents (Mamauag, et al.). Mamauag, et al. appealed to the National Appellate Board (NAB), which dismissed their appeal for late filing and lack of merit. They then filed a petition with the Court of Appeals, which set aside the PNP Chief’s and NAB’s rulings.
ISSUE
Whether the Court of Appeals erred in reversing the administrative rulings and in ordering the reinstatement of the police respondents.
RULING
The Supreme Court affirmed the Court of Appeals with modification. The legal logic centered on the principle of finality of administrative findings when supported by substantial evidence and the absence of grave abuse of discretion. The Court found that the initial investigation by the CPDC-ILAD, which recommended exoneration, was thorough and its findings were supported by evidence. The subsequent reversal by the PNP Chief was not justified, as the charges of Grave Misconduct were not substantiated. The acts of the police respondents—recording a complaint, facilitating a medical exam, and turning over minors to DSWD—were within their official duties and did not constitute misconduct, especially given the minors’ vulnerable condition requiring protective custody.
The NAB’s dismissal of the appeal for late filing was erroneous, as the police respondents had timely sought judicial recourse after the PNP Chief’s final resolution. More critically, the Supreme Court emphasized that where the exonerating findings of the initial disciplining authority (the CPDC District Director) are supported by evidence, and no new evidence justifies reversal, such initial decision should stand. Since the offense charged was not proven, the dismissal was unlawful. Consequently, the Court reinstated the CPDC’s original dismissal of the charges and granted the respondents entitlement to back wages and benefits under Section 48 of Republic Act No. 6975 .