G.R. No. 241074 . August 22, 2022.
PETER Q. MARISTELA, PETITIONER, VS. JOSE MARIA M. MIRASOL, RESPONDENT.

FACTS

Respondent Jose Maria M. Mirasol filed a complaint with the Office of the Ombudsman against petitioner Peter Q. Maristela, a City Councilor of Puerto Princesa, Palawan. Mirasol accused Maristela of bribing Barangay Captain Rene Godoy with PHP 25,000.00 and promises of uninterrupted project approvals in exchange for Godoy’s vote for a candidate in the Association of Barangay Councils (ABC) election. The alleged bribe was handed over in two tranches during meetings witnessed and secretly video-recorded by Godoy’s driver, John Inocencio. The Ombudsman found Maristela administratively liable for Conduct Prejudicial to the Best Interest of the Service and imposed a penalty of suspension from office without pay for nine months and one day.
Maristela denied the allegations, arguing they were hearsay and that the evidence was obtained in violation of his privacy rights under the Anti-Wire Tapping Law. He claimed the meetings were premeditated setups by Godoy and Inocencio, who were biased against him. The Court of Appeals affirmed the Ombudsman’s ruling, holding that the absence of audio in the recording placed it outside the scope of the Anti-Wire Tapping Law and that substantial evidence supported the finding of liability. Maristela elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals correctly affirmed the finding that petitioner Peter Q. Maristela is administratively liable for Conduct Prejudicial to the Best Interest of the Service.

RULING

The Supreme Court denied the petition and affirmed the assailed rulings. The Court held that in administrative proceedings, only substantial evidence—such relevant evidence as a reasonable mind might accept as adequate to support a conclusion—is required to establish liability. The factual findings of the Ombudsman, when supported by substantial evidence and affirmed by the Court of Appeals, are accorded great weight and respect and are deemed conclusive. In this case, both the Ombudsman and the appellate court uniformly found that Maristela offered money to influence an election, an act which tarnishes the integrity of public office.
The Court rejected Maristela’s defenses. It ruled that the alleged premeditation or ill motive of the complainants does not exonerate him; the crucial fact remains that he willfully engaged in the act of offering money. The Court also clarified that the secret video recording, which lacked an audio component, did not violate the Anti-Wire Tapping Law. Regardless, the Ombudsman did not rely on the video but on the firsthand affidavits of witnesses who were present during the transactions. As a public official, Maristela is held to a high standard of conduct. The mere act of offering money, irrespective of its intended purpose as vote-buying or otherwise, is sufficient to constitute Conduct Prejudicial to the Best Interest of the Service, as it undermines public trust in the government. The penalty of suspension was thus upheld.