GR 214435; (February, 2022) (Digest)
G.R. No. 214435 . February 14, 2022.
PROFESSIONAL REGULATION COMMISSION, PETITIONER, VS. DAYAMON DIDATO ALO, RESPONDENT.
FACTS
Respondent Dayamon Didato Alo, a public school teacher, was formally charged before the Board for Professional Teachers (Board) of the Professional Regulation Commission (PRC) for unprofessional and/or dishonorable conduct. The charge alleged she used a falsified Board Resolution No. 671 dated September 28, 2000 to obtain her certificate of registration and professional license as a teacher on September 14, 2007, as her name was not included in the original resolution. Alo defended herself by stating she applied for her license under Section 26(C) of Republic Act No. 7836 , which allows registration without examination for qualified teachers, and asserted she never submitted nor knew of the alleged falsified board resolution. She argued the PRC could have verified the document’s authenticity from its own records. The Board found her guilty and revoked her certificate and license. Alo filed a motion for reconsideration, which was denied. Instead of appealing to the PRC, she directly filed a petition for review with the Court of Appeals (CA). The CA reversed the Board’s decision, exonerating Alo. It found the evidence insufficient, noting the special prosecutor failed to present the alleged falsified board resolution or the authentic original copy, thus failing to prove the corpus delicti of falsification. The CA also held the Board erroneously applied a disputable presumption under the Rules of Court. The PRC then filed a petition for review on certiorari before the Supreme Court.
ISSUE
Whether the Court of Appeals erred in reversing the decision of the Board for Professional Teachers and exonerating respondent Dayamon Didato Alo from the charge of using a falsified board resolution to obtain her professional teacher’s license.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The Court held that the Board for Professional Teachers’ decision was not supported by substantial evidence. The special prosecutor failed to present the alleged falsified Board Resolution No. 671 or the authentic original copy as evidence. Without these documents, there was no proof of the corpus delicti of the falsification charge. The Court also found the Board’s application of the disputable presumption under Rule 131, Section 3(j) of the Rules of Court to be misplaced, as Alo was not accused of falsifying the license itself but of submitting a falsified board resolution to obtain it, and the license issued was authentic. Furthermore, the Court noted that Alo could have applied for registration under Section 26(C) of R.A. No. 7836 based on her qualifications, making the submission of a board resolution unnecessary. The charge against Alo was therefore not proven by substantial evidence.