GR 161086; (November, 2006) (Digest)
G.R. No. 161086 ; November 24, 2006
CIVIL SERVICE COMMISSION, Petitioner, vs. COURT OF APPEALS and LUZVIMINDA M. MANIAGO, Respondents.
FACTS
A Commission on Audit (COA) fraud audit of Infanta, Pangasinan, revealed that the Municipal Treasurer granted loans to municipal officers and employees, including Municipal Accountant Luzviminda M. Maniago, in violation of COA Circular 90-331. Maniago had an outstanding loan balance of ₱17,200.00 during the audit but had fully paid it by the time the Fraud Audit Report was submitted. Based on this report and a subsequent complaint by a resident, the Acting Mayor found Maniago guilty of Grave Misconduct and dismissed her. The Civil Service Commission (CSC), on appeal, modified the finding to Conduct Grossly Prejudicial to the Best Interest of the Service and imposed a one-year suspension.
Maniago then filed a petition for certiorari under Rule 65 with the Court of Appeals, instead of a petition for review under Rule 43. The appellate court, relaxing the rules, gave due course to the petition. It reversed the CSC, finding no substantial evidence to hold Maniago liable. It reasoned that the Fraud Audit Report did not establish that her personal loan caused the cash shortage or that she knowingly borrowed from public funds, noting she was not indicted by the Ombudsman. The CSC filed this petition for review.
ISSUE
1. Whether the Court of Appeals erred in entertaining Maniago’s petition for certiorari under Rule 65.
2. Whether there is substantial evidence to hold Maniago administratively liable.
RULING
The Supreme Court granted the CSC’s petition, reversing the Court of Appeals. On the procedural issue, the Court held that a special civil action for certiorari under Rule 65 is not a substitute for a lost appeal. Since Maniago had the plain, speedy, and adequate remedy of a petition for review under Rule 43, her resort to certiorari was improper. The Court of Appeals erred in relaxing the rules, as no compelling reason justified such liberality.
On the substantive issue, the Court found substantial evidence to support the CSC’s finding of administrative liability. The Fraud Audit Report, coupled with the Municipal Treasurer’s admission during the COA interview, established that the loan granted to Maniago came from municipal funds. The diversion of public funds for personal loans, even if fully repaid, constitutes Conduct Grossly Prejudicial to the Best Interest of the Service, as it deprives the municipality of the productive use of its funds. The Court emphasized that in administrative proceedings, technical rules of evidence are not strictly applied, and the findings of quasi-judicial agencies like the CSC, when supported by substantial evidence, are accorded respect and finality. Maniago’s payment and non-indictment by the Ombudsman do not absolve her of administrative liability.