G.R. No. 217862. July 04, 2023
CAMILO L. SABIO, PETITIONER, VS. ALAIN BAGUISI, MA. KRISTINA C. PONTI, AND LEANDER P. MARQUEZ, RESPONDENTS.

FACTS

This administrative case stems from petitioner Camilo L. Sabio’s intervention in a case pending before the Court of Appeals (CA) in 2008, where he was the Chair of the Presidential Commission on Good Government (PCGG). The case involved a petition for certiorari and injunctive relief filed by officials of Manila Electric Company (Meralco) against the Securities and Exchange Commission and the Government Service Insurance System (GSIS). Petitioner’s brother, Justice Jose L. Sabio, Jr., was an incumbent CA Justice who, after a series of raffles and an inhibition, was assigned as the Acting Chairperson of the Ninth Division handling the Meralco case.
On May 30, 2008, while at the Davao City Airport, petitioner received a call from Atty. Jesus I. Santos, a GSIS Board of Trustee member, informing him of the case and that his brother was the chair of the division to which it was assigned. Atty. Santos requested petitioner’s help. Petitioner, aware of the controversy, subsequently called his brother, Justice Sabio, confirmed his assignment, and tried to convince him “of the rightness of the stand of the GSIS and the SEC,” asking him to help the GSIS as it “represents the interest of the poor people.” Justice Sabio responded that he would vote according to his conscience.
These incidents led to a disciplinary action. In a prior related case, Re: Letter of Presiding Justice Conrado M. Vasquez, Jr., the Court found several CA Justices administratively liable and also addressed petitioner’s act, stating it “to influence the judgment of a member of the Judiciary” was “reprehensible.” The Office of the Ombudsman later found petitioner guilty of Grave Misconduct and Conduct Prejudicial to the Best Interest of the Service, imposing the penalty of dismissal. The Court of Appeals affirmed this decision.

ISSUE

Whether the Court of Appeals erred in affirming the Office of the Ombudsman’s decision finding petitioner Camilo L. Sabio guilty of Grave Misconduct and Conduct Prejudicial to the Best Interest of the Service and imposing the penalty of dismissal.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals Decision. The Court held that the petition, being one for review on certiorari under Rule 45, is limited to reviewing errors of law. Petitioner’s arguments, which essentially questioned the factual findings of the Office of the Ombudsman as affirmed by the CA, are beyond the scope of this mode of review. The factual findings of the Ombudsman, when supported by substantial evidence and affirmed by the CA, are conclusive.
The Court found no reason to deviate from these established facts. It reiterated its condemnation of petitioner’s act from the prior administrative case, Re: Letter of Presiding Justice Conrado M. Vasquez, Jr., where it was declared “reprehensible.” The Court emphasized that as a high-ranking government official, petitioner’s attempt to influence his brother, a sitting judge, in a pending case constituted a blatant disregard of ethical standards and the principle of judicial independence. Such act undermined public confidence in the integrity of the judiciary and the entire government.
The penalty of dismissal was found to be appropriate. It carries the accessory penalties of cancellation of eligibility, perpetual disqualification from holding public office, forfeiture of retirement benefits (except terminal leave and personal GSIS contributions), and bar from taking civil service examinations. The Court also noted that petitioner had previously been dismissed from service in a separate administrative case, which only reinforced the propriety of the penalty in this case.