GR 164460; (June, 2006) (Digest)
G.R. No. 164460 ; June 27, 2006
OFFICE OF THE OMBUDSMAN, Represented by Hon. SIMEON V. MARCELO, Petitioner, vs. CARMENCITA D. CORONEL, Respondent.
FACTS
Respondent Carmencita D. Coronel, a Senior Accounting Processor designated as Officer-in-Charge of the Linamon Water District, hosted a luncheon meeting for water district officers and LWUA advisors on October 14, 1998. She paid P1,213.00 for the meal, as shown by Cash Invoice No. 0736, and was reimbursed for this amount on November 13, 1998. Subsequently, the newly appointed General Manager, Pedro C. Sausal, Jr., filed a complaint for dishonesty against Coronel with the Office of the Ombudsman. He alleged that she falsified the receipt for reimbursement, claiming P1,213.00 when the original duplicate copy of the invoice supposedly reflected only P213.00.
The Graft Investigation Officer initially found Coronel guilty of dishonesty and ordered her dismissal. Upon her motion for reconsideration, the same officer exonerated her. However, the Ombudsman disapproved this exoneration order, reinstating the dismissal. The Court of Appeals nullified the Ombudsman’s disapproval, reinstating the exoneration. The Ombudsman elevated the case to the Supreme Court.
ISSUE
Whether the Office of the Ombudsman committed grave abuse of discretion in finding respondent Carmencita D. Coronel guilty of dishonesty based on the evidence presented.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The ruling emphasized that in administrative proceedings, a finding of guilt must be supported by substantial evidence. The sole evidence against Coronel was an unauthenticated photocopy of an alleged duplicate receipt showing the amount as P213.00. The Court held that this photocopy, absent any authentication, was inadmissible in evidence and carried no probative value whatsoever. It could not substantiate the charge of falsification and dishonesty.
The Court further ruled that the Ombudsman’s disapproval of the exoneration order, which disregarded the investigating officer’s factual finding of innocence and the corroborating affidavits from meeting attendees submitted by Coronel, was rendered with grave abuse of discretion. The Ombudsman’s action was arbitrary, as it relied on incompetent evidence while ignoring evidence that supported the respondent’s claim. Consequently, the charge was not proven by substantial evidence, warranting Coronel’s exoneration.