G.R. No. 197299; February 13, 2013
OFFICE OF THE OMBUDSMAN, Petitioner, vs. RODRIGO V. MAPOY and DON EMMANUEL R. REGALARIO, Respondents.

FACTS

Respondents Rodrigo V. Mapoy and Don Emmanuel R. Regalario, Special Investigators of the National Bureau of Investigation (NBI), implemented a search warrant against Pocholo Matias, seizing imported rice. After the warrant was quashed, Matias complained that respondents extorted money from him. On October 8, 2003, the Counter Intelligence Special Unit of the National Capital Regional Police Office (CISU-NCRPO) arrested respondents at Century Park Hotel in an entrapment operation, recovering marked money from Regalario. The NBI filed an administrative complaint for Dishonesty and Grave Misconduct. Respondents claimed they were conducting their own legitimate entrapment operation against Matias for corruption of public officials, asserting that Matias had offered them money and issued death threats.
The Office of the Ombudsman found respondents guilty, imposing dismissal with forfeiture of benefits. It found substantial evidence, crediting the regularity of the police entrapment and noting inconsistencies in respondents’ defense. The Court of Appeals reversed, applying the equipoise rule due to alleged unclear events and Matias’s suspect motive, thereby acquitting respondents. The Ombudsman filed this petition for review.

ISSUE

Whether the Court of Appeals erred in reversing the Ombudsman’s finding of administrative liability for Grave Misconduct and Dishonesty.

RULING

Yes, the Supreme Court reversed the Court of Appeals and reinstated the Ombudsman’s decision. The Court held that substantial evidence supported the administrative charges. The legal logic centered on evaluating the evidence and the presumption of regularity in official duties. The CISU-NCRPO’s entrapment was well-planned, with marked money duly recorded, and no ill motive was shown against the arresting officers. In contrast, respondents’ claim of a legitimate entrapment was unsubstantiated. Their Disposition Form only requested further investigation, not an entrapment, and lacked approval from the NBI Director, who even initiated the complaint against them. Their conduct—allowing Matias to leave after handing over money—was inconsistent with a genuine intent to arrest for corruption. The presence of their alleged NBI team members was not established, and they failed to promptly report the incident. The equipoise rule, which applies when evidence is evenly balanced, was misapplied by the CA as the preponderance of evidence pointed to respondents’ guilt. Thus, their actions constituted Grave Misconduct and Dishonesty, warranting dismissal.