G.R. No. 188066, October 22, 2014
OFFICE OF THE OMBUDSMAN, Petitioner, vs. CYNTHIA E. CABEROY, Respondent.

FACTS

Respondent Cynthia E. Caberoy, the principal of Ramon Avanceña National High School (RANHS) in Iloilo City, was charged administratively with Oppression and violation of Section 3(e) and (f) of Republic Act No. 3019 (the Anti-Graft and Corrupt Practices Act) by complainant Angeles O. Tuares. The complaint alleged that Caberoy withheld Tuares’ salary for June 2002. The Office of the Ombudsman-Visayas, in a Consolidated Decision dated June 30, 2005, found Caberoy guilty of Oppression and imposed the penalty of dismissal from service, including cancellation of civil service eligibility, forfeiture of benefits, and disqualification from reemployment. The Ombudsman concluded that Tuares was singled out and not paid her June 2002 salary due to her failure to submit a clearance and Performance Appraisal Sheet for Teachers (PAST), while other teachers were paid. Caberoy filed a petition for certiorari with the Court of Appeals (CA), which reversed the Ombudsman’s decision and absolved her of any liability. The CA found that Tuares eventually received her June 2002 salary, albeit delayed, and that Caberoy’s withholding of the salary was justified due to Tuares’ failure to submit required documents. The Ombudsman then filed this petition for review.

ISSUE

Whether the Court of Appeals erred in reversing the Ombudsman’s decision finding respondent Cynthia E. Caberoy administratively liable for Oppression.

RULING

The Supreme Court DENIED the petition and upheld the Court of Appeals’ decision absolving respondent Caberoy. The Court held that the CA correctly reversed the Ombudsman’s findings, as there was no substantial evidence to support the charge of Oppression. The Court emphasized that Oppression, or grave abuse of authority, requires proof of acts of cruelty, severity, or excessive use of authority. In this case, the evidence showed that Tuares received her June 2002 salary, though delayed, and that Caberoy’s action was justified because Tuares failed to submit the required clearance and PAST, which are necessary for salary disbursement. The Court noted that Caberoy’s duty to ensure compliance with documentation requirements was a reasonable exercise of her authority and not oppressive. Additionally, the Court found that the element of undue injury for violation of R.A. No. 3019 was absent, as Tuares ultimately received her salary. The Court concluded that the Ombudsman’s findings were not supported by substantial evidence and that the CA committed no reversible error in exonerating Caberoy.