GR L 61676; (October, 1982) (Digest)
G.R. No. L-61676 October 18, 1982
Editha B. Saligumba, petitioner, vs. Commission on Audit and Leonardo Estella, respondents.
FACTS
Petitioner Editha Saligumba filed a sworn complaint with the Commission on Audit (COA), charging respondent Leonardo Estella, an Auditing Examiner III, with disgraceful and immoral conduct for allegedly raping her on several occasions. The COA instituted Administrative Case No. 81-525 against Estella based on this complaint.
After proceedings, the COA rendered a decision on April 12, 1982, dismissing the charge against Estella for insufficiency of evidence. The COA, however, issued a warning to Estella to comport himself properly to avoid similar complaints in the future. Dissatisfied, Saligumba filed this petition for review, insisting the COA decision contradicted the evidence and raising multiple issues concerning the credibility of witnesses, the alleged acts, and even suggesting bias in the investigation.
ISSUE
Whether the Supreme Court can review the decision of the Commission on Audit in an administrative case involving the discipline of a COA personnel.
RULING
The Supreme Court dismissed the petition. The Court held it lacked jurisdiction to review the COA’s decision in this administrative disciplinary case. The Court’s power of review over COA decisions is statutorily limited to matters involving the settlement of accounts or money claims against the government. Disciplinary cases concerning COA personnel fall under the COA’s exclusive administrative jurisdiction as part of its constitutional autonomy.
Even assuming, for argument’s sake, that the Court could exercise review over such administrative matters, the petition would still fail. Saligumba’s petition essentially sought a re-evaluation of the factual findings of the COA, specifically the credibility of witnesses and the weight of evidence. The Supreme Court’s review power is confined to questions of law, not questions of fact. It cannot re-examine the evidentiary conclusions of an administrative body like the COA absent a showing of grave abuse of discretion amounting to lack or excess of jurisdiction, which was not sufficiently established. Therefore, the petition was dismissed for lack of jurisdiction.