GR 166116; (March, 2006) (Digest)
G.R. No. 166116 ; March 31, 2006
OFFICE OF THE OMBUDSMAN, Petitioner, vs. FLORENTINA SANTOS, Respondent.
FACTS
Respondent Florentina Santos, a public school principal, was administratively charged before the Office of the Ombudsman for dishonesty, violation of Republic Act No. 6713 (Code of Conduct and Ethical Standards), and grave misconduct. The charges stemmed from allegations that she falsified her Daily Time Record (DTR) by indicating she was at her official station on August 20, 1997, when witnesses testified she attended an event at Golden Child Montessori, a private school where she served as President and incorporator. Additional charges involved her alleged rude behavior and, in a supplemental complaint, the unauthorized taking of galvanized iron sheets from the public school, which were later recovered from a person she instructed.
Respondent denied the charges. She claimed her DTR entries differed from the security log because she inspected the school’s outer premises before logging in. For August 20, she asserted she had verbal permission from her district supervisor to attend the private school event. Regarding the iron sheets, she contended they were excess materials legally purchased from the contractor. The Ombudsman found her guilty and imposed the penalty of dismissal. The Court of Appeals reversed, finding the evidence insufficient to prove the charges with substantial evidence.
ISSUE
Whether the Court of Appeals erred in reversing the Ombudsman’s finding of administrative liability against respondent.
RULING
Yes, the Supreme Court reinstated the Ombudsman’s decision. The Court held that the Ombudsman’s factual findings, when supported by substantial evidence, are accorded respect and finality. Substantial evidence, which is that amount of relevant evidence a reasonable mind might accept as adequate to support a conclusion, was present. The discrepancy between respondent’s DTR and the security logbook for August 20, 1997, was clearly established, and her defense of having prior permission was unsubstantiated. Her active role in the private school, including handling its finances, also raised serious conflict-of-interest concerns under RA 6713.
Regarding the galvanized iron sheets, the testimonial and documentary evidence showed she directed their removal from the school premises to her residence under questionable circumstances, contradicting her claim of a legitimate purchase. The Court found the Ombudsman’s assessment of witness credibility and the collective weight of the evidence to be persuasive. Consequently, the administrative penalties imposed by the Ombudsman were reinstated, with the modification of an additional fine of Five Thousand Pesos (P5,000.00) for the violation of RA 6713.