GR 188909; (September, 2014) (Digest)
G.R. No. 188909 September 17, 2014
Republic of the Philippines, represented by the Office of the President, Department of Public Works and Highways and Presidential Anti-Graft Commission, Petitioners, vs. Florendo B. Arias, Assistant Director, Bureau of Equipment, Department of Public Works and Highways, Respondent.
FACTS
Respondent Florendo B. Arias was the Assistant Bureau Director of the Bureau of Equipment (BOE), Department of Public Works and Highways (DPWH). He, along with other DPWH officials, was formally charged by the Presidential Anti-Graft Commission (PAGC) in connection with anomalous emergency repairs of DPWH motor vehicles for Calendar Year 2000-2001. The charges included violation of the General Appropriations Act, the Anti-Graft and Corrupt Practices Act (R.A. No. 3019), the Code of Conduct and Ethical Standards for Public Officials and Employees (R.A. No. 6713), and a Presidential Memorandum on command responsibility. Specific allegations against Arias included: recommending approval of 24 Requisitions for Supplies and/or Equipment (RSE) for two vehicles not requested or certified by the end-users; signing the Request of Obligation and Allotment and approving Reports of Waste Material for these vehicles despite knowing no actual repairs were done; and affixing his signature on Disbursement Vouchers for payment without authority and despite knowledge of the absence of repairs. The total amount paid for the purported repairs for three specific vehicles was ₱832,140.00.
ISSUE
Whether the Supreme Court can review the factual findings of the Office of the President, which affirmed the PAGC’s decision finding respondent Arias guilty of grave misconduct and imposing the penalty of dismissal.
RULING
No. The petition was denied. The Supreme Court held that it is not a trier of facts. In administrative cases, factual findings of administrative bodies, when affirmed by the Office of the President, are accorded great weight and respect, and are deemed final and conclusive if supported by substantial evidence. The Court found no compelling reason to deviate from this rule, as the petitioners failed to demonstrate that the Office of the President’s findings were not supported by evidence or were arrived at arbitrarily. The Court emphasized that its jurisdiction is limited to reviewing errors of law, not re-examining the evidence. The factual conclusions of the Office of the President, which found Arias guilty, are binding.