Facts:

• Police officers Nestor M. Cayago and Virgilio M. Ferrer were dismissed from the Philippine National Police (PNP) for grave misconduct, specifically kidnapping for ransom.
• An Information was filed against them on January 30, 1995, in the Regional Trial Court of Quezon City.
• PNP Chief Recaredo A. Sarmiento II confirmed their dismissal on July 24, 1995, based on substantial evidence.
• The petitioners filed a motion for reconsideration but chose to appeal to the National Appellate Board (NAB) of the National Police Commission (NAPOLCOM) before the motion was resolved.
• On July 17, 1996, the NAB affirmed their dismissal, and the petitioners did not seek reconsideration of this decision.
• The Quezon City RTC later dismissed the criminal charges against them due to insufficient evidence, but this did not affect their administrative liability.
• Their appeals to various administrative bodies, including the Civil Service Commission (CSC), were dismissed on procedural grounds.
• The Secretary of the Department of the Interior and Local Government (DILG) upheld the dismissal, prompting the petitioners to seek review from the Court of Appeals and subsequently the Supreme Court.

Issue:

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Ruling:

• The Supreme Court denied the petition for review, affirming the Court of Appeals' decision, which upheld the NAB's ruling and the DILG Secretary's dismissal of the petitioners.
• The Court concluded that the NAB had jurisdiction...(Unlock)

Ratio:

• The Supreme Court stated that the NAB had exclusive appellate jurisdiction over disciplinary actions imposed by the PNP Chief.
• The petitioners' appeal to the NAB was interpreted as an abandonment of their pending motion for reconsideration with the PNP Chief.
• The Court noted that the petitioners had ample o...continue reading