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 CCIE 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 approval authority resided solely with the PMC Commandant.
In his defense, Miranda argued that his approval of the vouchers was merely ministerial, as all supporting documents were complete, and he claimed he was authorized by the Commandant to do so. 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, finding no substantial evidence to prove Miranda’s guilt. The CA held that his act of approving the vouchers, based on complete supporting documents, was a discretionary function performed in good faith and did not constitute misconduct. The FFIB elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals erred in reversing the Ombudsman’s finding of guilt for grave misconduct and dishonesty against respondent Renato P. Miranda.

RULING

The Supreme Court denied the petition and affirmed the Decision of the Court of Appeals. The Court emphasized that in administrative cases, the quantum of proof required is substantial evidence, or such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. The Court found that the Ombudsman’s ruling was based primarily on the premise that Miranda lacked authority to approve the disbursement vouchers. However, the evidence showed that the vouchers were accompanied by all necessary supporting documents, including the required allotment and obligation slips.
The Court ruled that Miranda’s act of approving the vouchers under these circumstances was an exercise of a discretionary duty, not a ministerial one. For an act to be considered ministerial, the officer must be required by law to perform a specific task in a prescribed manner upon the existence of specific facts, without any room for judgment. Here, Miranda had to examine the completeness and propriety of the documents before approval, which involved discretion. The Court further held that there was no evidence proving that Miranda acted with corrupt intent or in bad faith. Mere approval of the vouchers, without proof that he knowingly participated in a scheme to defraud or that he personally benefited from the irregularity, is insufficient to establish grave misconduct or dishonesty. The absence of proof of conspiracy with other officers also weakened the administrative case against him. Consequently, the finding of guilt was not supported by substantial evidence.