G.R. No. 187317 ; April 11, 2013
CARLITO C. ENCINAS, Petitioner, vs. PO1 ALFREDO P. AGUSTIN, JR., and PO1 JOEL S. CAUBANG, Respondents.

FACTS

Petitioner Carlito C. Encinas was the Provincial Fire Marshall of Nueva Ecija. Respondents, Fire Officers Alfredo P. Agustin, Jr. and Joel S. Caubang, alleged that on March 11, 2000, Encinas demanded ₱5,000 from them, threatening to transfer them to far-flung stations (Cuyapo and Talugtug, respectively) if they failed to pay. On March 15, 2000, they paid ₱2,000 at the house of a certain “Myrna,” with Encinas directing them to produce the balance within a week. When they failed to deliver the balance, Encinas issued their reassignment orders.
Respondents filed a letter-complaint with the Bureau of Fire Protection (BFP) on March 27, 2000, for illegal transfer under R.A. No. 6975 , which was later docketed for preliminary investigation under R.A. No. 3019 (Anti-Graft). They also filed a Joint Affidavit/Complaint with the Civil Service Commission Regional Office (CSCRO) on April 12 and 25, 2000, accusing Encinas of violating Section 4(A)(c) of R.A. No. 6713 (Code of Conduct). On October 27, 2000, the CSC formally charged Encinas with Dishonesty, Grave Misconduct, and Conduct Prejudicial to the Best Interest of the Service under the Administrative Code.
In his defense, Encinas claimed the reassignments were lawful, ordered by a superior (Supt. Simeon C. Tutaan) and due to respondents’ own misconduct—specifically, conducting unauthorized fire safety inspections and selling fire extinguishers. He cited a Confidential Investigation Report (July 31, 2000) recommending the dropping of charges against him. The BFP’s Internal Audit Services (IAS) later issued a Resolution (July 5, 2005) recommending dismissal of the administrative complaint against Encinas for insufficiency of evidence, ruling the reassignment was within managerial prerogative.
The CSCRO, however, found Encinas administratively liable based on respondents’ consistent testimonies, which constituted substantial evidence. It ordered his dismissal. The Civil Service Commission (CSC) and the Court of Appeals (CA) affirmed this ruling.

ISSUE

Whether the Court of Appeals erred in affirming the findings of the Civil Service Commission that petitioner Carlito C. Encinas was administratively liable for Grave Misconduct and Conduct Prejudicial to the Best Interest of the Service, warranting his dismissal from service.

RULING

The Supreme Court DENIED the petition and AFFIRMED the assailed Court of Appeals Decision and Resolution. The Court held that the findings of the CSC, affirmed by the CA, were supported by substantial evidence.
1. On Administrative Liability: The charges fell under Section 46(b)(4) and (27), Book V of the Administrative Code of 1987. The Court found that Encinas’s act of demanding money in exchange for retaining respondents’ assignments constituted Grave Misconduct, which involves a wrongful intention and a violation of a prescribed rule of action. It also constituted Conduct Prejudicial to the Best Interest of the Service, as it tarnished the image and integrity of the Bureau of Fire Protection.
2. On Substantial Evidence: In administrative proceedings, only substantial evidence—such relevant evidence as a reasonable mind might accept as adequate to support a conclusion—is required. The Court ruled that the detailed, consistent, and categorical testimonies of respondents Agustin and Caubang, describing the extortion attempt and partial payment, constituted substantial evidence to hold Encinas liable. The absence of documentary proof for the ₱2,000 payment did not negate liability, as the credible oral testimonies sufficed.
3. On the Defense of Lawful Reassignment: The Court held that Encinas’s defense—that the reassignments were due to respondents’ unauthorized activities and upon a superior’s order—did not disprove the accusation of extortion. The existence of a valid reassignment order does not negate the prior illegal act of demanding money to prevent it. The motives for the reassignment and the act of extortion are separate.
4. On the BFP-IAS Resolution: The Court noted that the BFP-IAS Resolution recommending dismissal for insufficiency of evidence was not binding on the CSC, as the CSC is the central personnel agency of the government with ultimate authority over civil service matters. The CSC’s factual findings, when affirmed by the CA, are generally conclusive and binding on the Supreme Court.
5. On the Penalty: Dismissal from service is the appropriate penalty for Grave Misconduct under the Uniform Rules on Administrative Cases in the Civil Service. This penalty carries the accessory penalties of cancellation of eligibility, forfeiture of retirement benefits (except accrued leave credits), and perpetual disqualification from reemployment in government service.
The Supreme Court found no reversible error in the CA’s judgment.