G.R. No. 216574 July 10, 2019
Fact-Finding Investigation Bureau (FFIB) – Office of the Deputy Ombudsman for the Military and Other Law Enforcement Offices, Petitioner, vs. Renato P. Miranda, Respondent.

FACTS

The Fact-Finding Investigation Bureau (FFIB) of the Ombudsman charged several Philippine Marine Corps (PMC) officers, including then Colonel Renato P. Miranda, with grave misconduct and dishonesty. The charges stemmed from the alleged anomalous disbursement of Combat Clothing and Individual Equipment (CCIE) allowances in 2000. A Commission on Audit (COA) investigation, through random sampling, revealed that numerous enlisted personnel did not receive their full allowances, disowned signatures on liquidation payrolls, and noted a deviation from standard payroll preparation procedures. The FFIB alleged that Miranda approved the disbursement vouchers for these funds without proper authority, as such authority resided solely with the PMC Commandant.
Miranda defended himself by asserting that he acted in a ministerial capacity. He claimed that the PMC Commandant, BGen. Percival Subala, had authorized him to approve the vouchers, and once all supporting documents were complete, he had no discretion but to approve them. The Office of the Deputy Ombudsman for the Military and Other Law Enforcement Offices (ODO-MOLEO) found Miranda guilty of grave misconduct and dishonesty and ordered his dismissal from service. The Court of Appeals (CA) reversed this ruling, absolving Miranda of administrative liability.

ISSUE

Whether the Court of Appeals erred in reversing the Ombudsman’s finding that respondent Renato P. Miranda is guilty of grave misconduct and dishonesty warranting dismissal from service.

RULING

The Supreme Court granted the petition and reinstated the Ombudsman’s decision, finding Miranda guilty of grave misconduct. The Court emphasized that factual findings of the Ombudsman, when supported by substantial evidence, are accorded respect and finality. The Ombudsman’s investigation established that Miranda approved the disbursement vouchers despite lacking the explicit authority mandated by the Government Accounting and Auditing Manual, which vested such power only in the head of office, the PMC Commandant. His defense of acting ministerially under the Commandant’s authorization was rejected.
The legal logic hinges on the nature of approval authority as a discretionary, not ministerial, act involving the examination of documents for propriety and legality. By approving the vouchers without the requisite authority, Miranda exercised a power not conferred upon him, facilitating the irregular release of funds. This act, coupled with the established fact that many intended beneficiaries did not receive their allowances, constituted grave misconduct, defined as a transgression of established rules involving wrongful intent. The Court found substantial evidence supporting the Ombudsman’s conclusion of administrative guilt, thereby overturning the CA’s reversal for having been made with grave abuse of discretion. The penalty of dismissal was reinstated.