G.R. No. 237521 , November 10, 2021
DEPARTMENT OF JUSTICE, PETITIONER, VS. RAMONSITO G. NUQUI, RESPONDENT.

FACTS

In February 2010, Rachel J. Ong, a former liaison officer of the Bureau of Immigration, executed sworn statements exposing corruption by a syndicate of Bureau of Immigration personnel at the Diosdado Macapagal International Airport. Among those implicated was Ramonsito G. Nuqui, a security guard and acting immigration officer. Ong alleged that Nuqui assisted in facilitating travel for passengers with incomplete or falsified documents for money and, on separate occasions, threatened to off-load women passengers unless they dated him. Following a preliminary investigation by a panel from the National Prosecution Service, National Bureau of Investigation, and Bureau of Immigration, which recommended filing administrative charges, the Department of Justice formally charged Nuqui and others with grave misconduct, conduct prejudicial to the best interest of the service, dishonesty, and gross neglect of duty. After investigation, where Ong testified and was cross-examined, the Department of Justice found Nuqui guilty and dismissed him from service. The Civil Service Commission affirmed this decision. Nuqui appealed to the Court of Appeals, which reversed the rulings, finding Ong’s testimony uncorroborated and inconsistent. The Department of Justice then filed this Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals erred in exonerating respondent Ramonsito G. Nuqui from the administrative charges based on its assessment of the credibility of the whistleblower’s testimony.

RULING

Yes. The Supreme Court reversed the Court of Appeals Decision and Resolution. The Court held that the findings of administrative agencies, when based on substantive evidence such as the credible testimony of a whistleblower, deserve great respect. The Court found that Ong’s testimony, based on her personal knowledge as a participant in the scheme, was credible and detailed, specifying the acts, participants, and location of the illegal transactions. The alleged inconsistencies in her statements were not material to the core allegations against Nuqui. The Court emphasized that in fighting corruption, the substance of a whistleblower’s testimony should be prioritized over their past actions or minor inconsistencies. Consequently, the Supreme Court reinstated the Department of Justice Resolution and the Civil Service Commission Decision and Resolution finding Nuqui guilty of the charges and imposing the penalty of dismissal from service with its accessory penalties.