Title
Alcala vs. Villar
Case
G.R. No. 156063
Decision Date
Nov 18, 2003
Teachers accused principal of dishonesty over forged checks and loyalty benefits; Ombudsman ruled against principal, but CA nullified due to jurisdiction. SC reinstated Ombudsman’s decision, citing estoppel, and remanded for merits review.
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Case Digest (G.R. No. 156063)

Facts:

1. Parties Involved:

  • Petitioners: Melecio Alcala, Perla Alcala, Roque Borinaga, Diosdada Borinaga, Helen Lendio, and Mary Babeth Magno (teachers at Lanao National High School and Dapdap National High School).
  • Respondent: Jovencio D. Villar (School Principal of Lanao National High School).

2. Allegations:

  • In February 1998, petitioners filed an administrative complaint against respondent for dishonesty.
  • They alleged that in August 1997, they attended a training/seminar and submitted Certificates of Appearance for reimbursement. Respondent gave them partial refunds, but they later discovered that DECS issued checks for P312.00 each, which respondent allegedly forged and encashed.
  • In November 1997, some petitioners received P1,500.00 as Loyalty Benefits but later found out they were entitled to P2,000.00 each.

3. Respondent’s Defense:

  • Respondent claimed he was authorized by the teachers to encash their checks at E and E Lending Investors due to the lack of banks in their rural area. He stated that deductions were made for existing loans.
  • He denied any wrongdoing regarding the Loyalty Benefits and alleged the complaint was filed to force his resignation.

4. Ombudsman’s Decision:

  • On June 22, 1999, the Ombudsman found respondent guilty of dishonesty and dismissed him from service with forfeiture of benefits and disqualification from public office.
  • Respondent’s motion for reconsideration was denied on October 13, 1999.

5. Court of Appeals Decision:

  • The Court of Appeals nullified the Ombudsman’s decision, ruling that the Ombudsman lacked jurisdiction over public school teachers under Republic Act No. 4670 (Magna Carta for Public School Teachers).
  • Petitioners’ motion for reconsideration was denied on October 25, 2002.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Jurisdiction of the Ombudsman:

    • Republic Act No. 4670 (Magna Carta for Public School Teachers) governs administrative proceedings involving public school teachers, not Republic Act No. 6770 (Ombudsman Act of 1989). The Ombudsman lacked jurisdiction over the case.
  2. Estoppel by Laches:

    • Respondent participated in the Ombudsman’s proceedings without raising jurisdictional objections. Under the principle of estoppel by laches, he is barred from challenging jurisdiction after an adverse decision.
  3. Due Process:

    • Respondent was afforded due process as he filed a counter-affidavit, participated in hearings, and cross-examined witnesses. The essence of due process in administrative proceedings is the opportunity to be heard, which was satisfied.
  4. Remand to Court of Appeals:

    • The Court of Appeals should have resolved the appeal on its merits instead of nullifying the Ombudsman’s decision based on jurisdiction. The case was remanded for proper determination.


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