G.R. No. 197307 ; February 26, 2014
FLOR GUPILAN-AGUILAR and HONORE R. HERNANDEZ, Petitioners, vs. OFFICE OF THE OMBUDSMAN, represented by HON. SIMEON V. MARCELO; and PNP-CIDG, represented by DIR. EDUARDO MATILLANO, Respondents.

FACTS

The PNP-CIDG filed an administrative complaint against petitioners Flor Gupilan-Aguilar, a Bureau of Customs official, and Honore Hernandez for Grave Misconduct and Dishonesty. The complaint alleged that Aguilar’s lifestyle was grossly disproportionate to her government salary. Investigation revealed she owned several properties not declared in her Statements of Assets, Liabilities and Net Worth (SALNs), including a condominium unit in Pasay City and a lot in Naga City. She also frequently traveled abroad with her daughters. The Ombudsman found her guilty and dismissed her from service, a decision affirmed by the Court of Appeals.
Aguilar contested the findings. She claimed the condominium was owned by her US-based brother, the Naga lot had been sold, and her foreign trips were sponsored by relatives. She argued the Ombudsman erred in finding her properties unlawfully acquired based merely on a disparity between her assets and salary, without proof of illegal origin. Hernandez similarly denied the allegations against him.

ISSUE

Whether the Ombudsman committed grave abuse of discretion in finding petitioners guilty of Grave Misconduct and Dishonesty and ordering their dismissal.

RULING

No. The Supreme Court denied the petition and affirmed the Ombudsman’s decision. The Court held that the Ombudsman’s factual findings, when supported by substantial evidence, are conclusive. In administrative cases, substantial evidence—such relevant evidence as a reasonable mind might accept as adequate to support a conclusion—is sufficient. The Ombudsman found such evidence in the glaring disproportion between Aguilar’s assets and expenditures and her legitimate income, which she failed to satisfactorily explain.
The legal logic is grounded in the presumption that properties acquired by a public officer during their incumbency, which are manifestly disproportionate to their lawful income, are prima facie unlawful. This presumption, arising from the constitutional and statutory duty to file truthful SALNs under Republic Act No. 6713 , places the burden on the officer to credibly explain the discrepancy. Aguilar’s defenses, such as ownership by relatives and gifts, were deemed insufficient and unsubstantiated. Her failure to declare assets in her SALNs constituted dishonesty, and the acquisition of unexplained wealth constituted grave misconduct. The Court found no grave abuse of discretion, as the Ombudsman’s conclusions were based on the evidence on record.