G.R. No. 223210 . November 6, 2017.
WILSON T. LIM, Petitioner, vs. P/S INSP. EUSTIQUIO FUENTES, Respondent.

FACTS

Petitioner Wilson T. Lim, a used car dealer, purchased vehicles from agent Raquim Salvo based on documents, including PNP Motor Vehicle Clearance Certificates (MVCCs) issued by respondent PSI Eustiquio Fuentes. These documents indicated the vehicles were not stolen. Lim later discovered the vehicles were carnapped and had to refund his buyers. He filed an administrative complaint for Grave Misconduct against Fuentes, alleging the MVCCs were falsified, enabling the fraud.
The Office of the Deputy Ombudsman for MOLEO initially found Fuentes guilty, ruling his issuance of an MVCC for a vehicle already listed as stolen in the national database was an act of bad faith constituting Grave Misconduct. However, the Ombudsman later reversed this, dismissing the complaint. It held that Fuentes’s function in issuing an MVCC was ministerial, relying on a certification from the PNP Crime Laboratory that the vehicle passed inspection and was not on the local stolen list. The Court of Appeals affirmed this reversal.

ISSUE

Whether respondent PSI Eustiquio Fuentes is administratively liable for Grave Misconduct in issuing the Motor Vehicle Clearance Certificate.

RULING

No. The Supreme Court denied the petition and affirmed the dismissal of the administrative complaint against Fuentes. The Court emphasized that Grave Misconduct requires a wrongful intent or a conscious disregard of duty. The evidence failed to establish that Fuentes acted with corruption, clear intent to violate the law, or flagrant disregard of established rules.
The Court agreed that Fuentes performed a ministerial duty. The MVCC was issued based on a prior macro-etching examination and certification by the PNP Crime Laboratory, which found no tampering and no record of the vehicle in its local list of stolen vehicles. Fuentes had no authority to re-examine the Crime Laboratory’s findings or to independently access the computerized Motor Vehicle Management Information System (MVMIS) maintained in Camp Crame. His reliance on the subordinate’s report and the laboratory certification was justified. Absent proof that he knowingly issued a false clearance or conspired with the car agent, his act did not amount to the deliberate wrongdoing or gross negligence required for a finding of Grave Misconduct. The Court upheld the findings of the Ombudsman, noting its expertise and the substantial evidence supporting its conclusion.