G.R. No. 240517 & 240688, June 27, 2023
Civil Service Commission and Paquito N. Ochoa, Jr., Executive Secretary, Petitioners, vs. Jerik Roderick V. Jacoba, Respondent. [G.R. No. 240688] Jerik Roderick V. Jacoba, Petitioner, vs. Civil Service Commission and Paquito N. Ochoa, Jr., Executive Secretary, Respondents.

FACTS

The case involves the administrative liability of Atty. Jerik Roderick V. Jacoba, an employee of the Office of the Deputy Executive Secretary for Legal Affairs, Office of the President, concerning the mishandling of the case records of the appeal of Manuel Jimenez III in the Ruby Rose Barrameda-Jimenez murder case. The records, which included a draft decision, went missing after being forwarded to Donabel Ronzales for proofreading on July 29, 2011. In February 2012, an inquiry revealed the records were lost. On May 2, 2012, the missing records were found inside a locked filing cabinet used by Jacoba. An Investigating Panel was created, which recommended charging Jacoba with Grave Misconduct and Serious Dishonesty. The Executive Secretary found Jacoba guilty and dismissed him from service. The Civil Service Commission affirmed this decision. Jacoba appealed to the Court of Appeals, which modified the finding, holding him guilty only of Simple Misconduct. Both the Civil Service Commission and Jacoba filed Petitions for Review before the Supreme Court.

ISSUE

Whether the Court of Appeals erred in modifying the finding of the Office of the President and the Civil Service Commission and holding Jacoba guilty only of Simple Misconduct instead of Grave Misconduct and Serious Dishonesty.

RULING

The Supreme Court denied the petitions and affirmed the Decision and Resolution of the Court of Appeals. The Court held that the findings of administrative bodies, when supported by substantial evidence, are accorded respect and finality. In this case, the Court of Appeals correctly found that the evidence only supported a finding of Simple Misconduct. The element of corruption, clear intent to violate the law, or flagrant disregard of established rule required for Grave Misconduct was not established. Similarly, the element of deliberate concealment or misrepresentation of a material fact required for Serious Dishonesty was not proven. The circumstantial evidence only showed that Jacoba failed to exercise due diligence in safeguarding the case records that came into his possession, constituting Simple Neglect of Duty, which is subsumed under Simple Misconduct. The penalty imposed by the Court of Appeals was modified to a six-month suspension without pay, considering Jacoba had already been dismissed and under preventive suspension.