G.R. No. 175451 ; April 13, 2007
ROSARIO L. DADULO, Petitioner, vs. THE HON. COURT OF APPEALS, OFFICE OF THE OMBUDSMAN, HON. FELICIANO BELMONTE, JR., in his capacity as City Mayor of Quezon City and GLORIA PATANGUI, Respondents.

FACTS

Petitioner Rosario Dadulo, Barangay Chairperson of Payatas A, Quezon City, was administratively charged before the Office of the Ombudsman by private respondent Gloria Patangui. Patangui alleged that on September 22, 2002, Dadulo, along with several Barangay Security Development Officers (BSDOs), unlawfully seized construction materials (galvanized iron sheets, lumber, and plain iron sheets) from her backyard without her consent. The complaint was supported by the sworn statements of Patangui and her nine-year-old daughter, Jessica, who witnessed the taking. Patangui later identified some of the seized materials, bearing distinctive campaign stickers, as being used in the construction of a new barangay outpost.
In her defense, Dadulo denied the allegations. She claimed the inspection was a legitimate barangay action to verify building permits, asserting that Patangui was illegally constructing on government land owned by NAWASA. The BSDOs corroborated this, stating they acted courteously during the inspection and that the complaint was fabricated.

ISSUE

Whether there is substantial evidence to hold petitioner Rosario Dadulo administratively liable for conduct prejudicial to the best interest of the service.

RULING

The Supreme Court affirmed the findings of the Office of the Ombudsman and the Court of Appeals, ruling that substantial evidence supports petitioner’s administrative liability. In administrative proceedings, the quantum of proof required is substantial evidence—such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. The Court found that the positive and categorical testimonies of complainant Patangui and her daughter, who identified Dadulo as the person who ordered the seizure, constituted substantial evidence. The corroborative detail that the seized materials were later found used in a barangay project strengthened the claim. Petitioner’s defense of a general denial and claim of a legitimate inspection failed to rebut this direct evidence. The Court emphasized that it is not its function to re-evaluate factual findings of administrative agencies supported by substantial evidence, absent a showing of grave abuse of discretion. Thus, the penalty of six months suspension for conduct prejudicial to the best interest of the service was upheld.