GR L 42620; (April, 1985) (Digest)
G.R. No. L-42620 April 30, 1985
MAXIMINO RUELAN, petitioner, vs. CIVIL SERVICE COMMISSION; MINISTER OF PUBLIC WORKS, TRANSPORTATION AND COMMUNICATIONS; and THE POSTMASTER GENERAL, respondents.
FACTS
Petitioner Maximino Ruelan, the Postmaster of Tabuelan, Cebu, was administratively charged with dishonesty, oppression, and grave misconduct. The complaint, filed by Angela Loyao in 1968, alleged that Ruelan, exploiting her illiteracy and old age, facilitated the encashment of her USVA benefit check worth $4,686.50. He gave her only P5,000, deposited P10,000 in a joint account under his wife’s and Loyao’s names without her knowledge, and kept the remaining balance. Although Loyao later executed an affidavit of desistance in 1970, claiming she was misled and that Ruelan had fully settled his debt, the Postmaster General proceeded with the charges. After investigation, the Acting Secretary of Public Works found Ruelan guilty and dismissed him from service, a decision affirmed by the Civil Service Commission.
ISSUE
The primary issue is whether the Civil Service Commission committed grave abuse of discretion in affirming Ruelan’s dismissal based on the evidence presented and the applicable civil service rules.
RULING
The Supreme Court dismissed the petition, upholding the dismissal. The Court found no grave abuse of discretion. While the Commission erred in applying Presidential Decree No. 6, which was promulgated after the 1968 incident, this error was not fatal. Ruelan’s act was properly punishable under the pre-existing Section 19(o) of the Revised Civil Service Rules, which prohibits contracting loans from persons with whom the office has business relations. The Court rejected Ruelan’s argument that his act did not constitute a violation because the potential for graft was remote, emphasizing that the rule is designed to prevent conflicts of interest and maintain ethical standards, regardless of whether actual corruption occurs.
On the sufficiency of evidence, the Court held that the findings were supported by substantial evidence from the administrative hearing. The factual determination that Ruelan borrowed money from Loyao, a constituent he served as postmaster, was sustained. The Court reiterated the constitutional principle that public office is a public trust, requiring the highest degree of integrity and accountability. Thus, the administrative penalty of dismissal was justified. The petition was dismissed for lack of merit.