Facts:

The case involves Corazon C. Balbastro, a former principal of the Iloilo City National High School (ICNHS) in Molo, Iloilo City, who is the appellee in this matter against the Commission on Audit, Regional Office No. VI (COA Region VI), the appellant. The events leading to this case began with a letter-complaint dated February 12, 1999, filed by the officers of the ICNHS Teachers and Employees Association against Balbastro. The Ombudsman-Visayas initiated a fact-finding investigation based on this complaint, which led to a comprehensive audit conducted by State Auditors Arlene T. Tagonon and Marie Elaine G. Dolorfino from January 1998 to March 1999. The audit report, submitted on August 16, 1999, revealed several irregularities attributed to Balbastro and Lydia Ocate, the Disbursing Officer of ICNHS. These included late remittances of GSIS, PAG-IBIG, and Medicare contributions, misappropriation of funds amounting to P184,536.76, unauthorized expenditures for unimplemented pro...

Facts:

1. Background of the Case:

   • Petitioner Corazon C. Balbastro, a former principal of Iloilo City National High School (ICNHS), was charged with Grave Misconduct and dismissed from government service.
   • The case stemmed from a letter-complaint filed by the ICNHS Teachers and Employees Association on February 12, 1999, prompting the Ombudsman-Visayas to request the Commission on Audit (COA) Regional Office No. VI to conduct a fact-finding investigation.

2. Audit Findings:

   • COA auditors Arlene T. Tagonon and Marie Elaine G. Dolorfino conducted a comprehensive audit of ICNHS accounts from January 1998 to March 1999.
   • The audit report revealed several irregularities:
     • Late remittance of GSIS, PAG-IBIG, and Medicare contributions.
     • Non-reflection of P184,536.76 in government funds, which were spent for unauthorized purposes.
     • Spending P161,150 for repair projects that were not implemented.
     • Disbursement of P467,254.55 for Ati-Atihan costumes, with only P48,275 spent on designer fees, and no appropriation for the amount.
     • Discrepancies in payrolls, with 50 laborers' names differing significantly from other payrolls.

3. Administrative and Criminal Cases:

   • The Ombudsman upgraded the inquiry into administrative (OMB-VIS-ADM-2000-0441) and criminal (OMB-VIS-CRIM-2000-0494) cases.
   • Petitioner filed an Answer and Supplemental Answer, claiming the charges were a duplication of a pending DECS case and denying the allegations.

4. Proceedings Before the Ombudsman:

   • Petitioner failed to attend two consecutive preliminary conferences, leading the Ombudsman to deem her as having waived her right to a formal hearing.
   • The Ombudsman found petitioner guilty of Grave Misconduct, except for the late remittances, and imposed the penalty of dismissal.

5. Appeal to the Court of Appeals:

   • The Court of Appeals initially ruled that the Ombudsman could only recommend sanctions, not impose them directly.
   • Upon reconsideration, the appellate court affirmed the Ombudsman's decision, citing the Ombudsman's authority to impose penalties.

6. Petition to the Supreme Court:

   • Petitioner argued that she was denied due process, claiming she was not furnished the sworn complaint and that the proceedings were irregular.
   • She also contended that the evidence did not support the Ombudsman's findings.

Issue:

1. Whether petitioner was denied due process in the proceedings before the Ombudsman.
2. Whether the Ombudsman's findings were supported by substantial evidence.
3. Whether the Ombudsman had the authority to directly impose the penalty of dismissal.

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Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Conclusion:

The Supreme Court upheld the Ombudsman's decision, finding petitioner guilty of Grave Misconduct and imposing the penalty of dismissal. The Court ruled that petitioner was not denied due process, the findings were supported by substantial evidence, and the Ombudsman had the authority to impose the penalty.