G.R. Nos. 172532 & 172544-45, November 20, 2013
PRIMO C. MIRO, in his capacity as Deputy Ombudsman for the Visayas, Petitioner, vs. MARILYN MENDOZA VDA. DE EREDEROS, CATALINA ALINGASA and PORFERIO I. MENDOZA, Respondents.

FACTS

Respondents Porferio I. Mendoza (Regional Director of LTO Cebu), Marilyn Mendoza Vda. de Erederos (his niece and secretary), and Catalina Alingasa (LTO clerk) were administratively charged with Grave Misconduct before the Deputy Ombudsman for the Visayas. Private complainants, who were liaison officers for various automotive companies, alleged a scheme wherein confirmation certificates—an indispensable requirement for motor vehicle registration and supposed to be free—were sold for ₱2,500 per pad. The collections were allegedly remitted by Alingasa to Erederos, and then to Mendoza. It was further alleged that confirmation certificates processed under the previous LTO administration were dishonored, forcing dealers to repurchase new ones.
In their defense, the respondents denied the accusations. Mendoza claimed the charges were instigated to replace him as Regional Director. Erederos and Alingasa denied collecting any money. Some complainants later executed affidavits of desistance, though one later retracted, claiming she was threatened. The Deputy Ombudsman found the respondents guilty of Grave Misconduct. The Court of Appeals (CA) reversed this decision, prompting the Deputy Ombudsman to elevate the case to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in reversing the factual findings and conclusions of the Deputy Ombudsman, who found the respondents guilty of Grave Misconduct.

RULING

The Supreme Court denied the petition and affirmed the CA’s decision. The Court held that the CA correctly found the evidence against the respondents insufficient to prove Grave Misconduct by substantial evidence. The core ruling is that the Ombudsman’s factual findings, while generally respected, are not binding when not supported by substantial evidence. In this case, the complainants’ allegations were primarily based on hearsay, as none of them personally witnessed the alleged remittance of money from Alingasa to Erederos or to Mendoza. Their claims were largely speculative, stating Alingasa “would usually remit” and Erederos “would, in turn, remit.”
The affidavits of desistance, while not automatically negating liability, further weakened the case by casting doubt on the complainants’ credibility and the voluntariness of their initial charges. The retraction by one complainant, detailing coercion, underscored the unreliability of the evidence. The Court emphasized that in administrative proceedings, the burden of proof lies with the complainant, and the quantum of proof required is substantial evidence—such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. The evidence presented, rife with inconsistencies and hearsay, failed to meet this standard. Consequently, the charges of Grave Misconduct were not proven.