Facts:

• The case "Cabotage v. Field Investigation Office, Office of the Ombudsman" involves petitioners Corazon C. Cabotage, Juanito B. Daguno, Jr., Violeta M. Gamil, Teresita E. Tam, Roberto P. Villa, and Vilma A. Tiongson.
• These petitioners are employees of the Commission on Audit (COA) assigned to the Local Water Utilities Administration (LWUA).
• LWUA is a government-owned and controlled corporation (GOCC) responsible for developing water supply systems outside Metropolitan Manila.
• On September 12, 2012, LWUA's Internal Control Office (ICO) reported irregular cash disbursements amounting to PHP 25 million from 2006 to 2010.
• These disbursements were recorded as "13th Month Pay and Other Bonuses" for government employees detailed to LWUA, including COA personnel.
• The Field Investigation Office (FIO) of the Office of the Ombudsman filed a complaint on August 4, 2014, against the petitioners.
• The complaint cited violations of Section 7(d) of Republic Act No. 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees) and Grave Misconduct under Section 46.A (3) and Conduct Prejudicial to the Best Interest of the Service under Section 46.B (8) of the Revised Rules on Administrative Cases in the Civil Service.
• The petitioners received various amounts of monetary benefits from LWUA, alleged to be without legal basis and in violation of R.A. No. 6758, which prohibits COA personnel from receiving additional compensation from any government entity.
• The Ombudsman found the petitioners guilty of Grave Misconduct and ordered their dismissal from service.
• The Court of Appeals (CA) affirmed the Ombudsman's decision but dismissed the administrative complaint against Proceso Saavedra and Evangeline Sison due to their retirement from service.
• The petitioners then filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, challenging the CA's decision.

Issue:

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Ruling:

1. The Supreme Court ruled that the receipt of monetary benefits from LWUA by the petitioners constitutes Grave Misconduct.
2. The Supreme Court affirmed that the penalty of dismissal from service is commensurate to the petitioners' infractions.
3. The Supreme Court upheld the CA's decision that the Ombudsm...(Unlock)

Ratio:

• The Supreme Court explained that misconduct involves a transgression of some established and definite rule of action, more particularly, unlawful behavior or gross negligence by a public officer.
• Grave Misconduct is characterized by elements of corruption, clear intent to violate the law, and flagrant disregard of established rules.
• The petitioners' actions demonstrated an intent to violate the law or a disregard of well-known rules, as they knowingly received pecuniary benefits from LWUA, which is prohibi...continue reading