G.R. No. 203696, June 2, 2014
JESSE PHILIP B. EIJANSANTOS, Petitioner, vs. SPECIAL PRESIDENTIAL TASK FORCE 156, represented by ATTY. ALLAN U. VENTURA, Respondent.

FACTS

The Special Presidential Task Force 156 (SPTF 156) investigated public officials of the One Stop Shop Inter-Agency Tax Credit and Duty Drawback Center of the Department of Finance for grave misconduct in connection with the anomalous issuance of thirty-four (34) Tax Credit Certificates (TCCs) amounting to at least ₱110,194,158.00 to Evergreen Weaving Mills, Inc. (Evergreen). Petitioner Jesse Philip B. Eijansantos was among the evaluators and examiners investigated. SPTF 156’s investigation revealed that Evergreen’s existence was questionable, its suppliers and buyers were non-existent, and the sales invoices and delivery receipts supporting its tax credit claims were fake. Based on a complaint-affidavit, SPTF 156 filed administrative charges for grave misconduct. The Office of the Ombudsman’s Prosecution and Monitoring Bureau found Eijansantos and others guilty of grave misconduct and imposed the penalty of dismissal. The Ombudsman ruled that the spurious documents could have been discovered if proper verification was conducted and that the officials’ acts, by simply accepting documents as authentic without further verification, facilitated a grand tax scam. Eijansantos argued before the Court of Appeals that he dutifully performed his evaluator duties based on the directives taught to him and that the documents appeared authentic. The CA affirmed the Ombudsman’s decision, noting that Eijansantos’s duties included the physical verification/inspection of manufacturing and plant facilities, which he admitted he did not perform, relying solely on documentary evaluation. The CA concluded this constituted deliberate dishonesty and grave misconduct.

ISSUE

Whether the Court of Appeals erred in affirming the Office of the Ombudsman’s finding that petitioner Jesse Philip B. Eijansantos is guilty of grave misconduct.

RULING

The Supreme Court denied the petition and affirmed the assailed decisions. The Court held that the factual findings of the Office of the Ombudsman, when supported by substantial evidence and affirmed by the Court of Appeals, are conclusive. The Court found that Eijansantos failed to perform his specific duty as an evaluator to conduct a physical verification/inspection of Evergreen’s manufacturing and plant facilities, relying merely on a documentary verification of the papers forwarded to him. This deliberate disregard of established rules, despite his job description explicitly requiring physical verification, constituted grave misconduct. The Court emphasized that public service requires the highest sense of honesty and dedication to duty, and as a revenue officer, Eijansantos was vested with the duty to guard against fraud upon the government. His failure to conduct the required ocular inspection led to a positive evaluation of Evergreen, which had no legitimate operations, resulting in a government loss of at least ₱867,680.00 from the TCC he evaluated. His entire act pointed to a deliberate disregard of established rules constitutive of grave misconduct.