G.R. No. 215545 - Dela Cruz vs. National Police Commission

In an October 15, 2001 Information, Sonny H. Villarias was charged with violation of Presidential Decree No. 1866 for allegedly possessing firearms without permits.
On October 13, 2001, police officers led by SPO4 Quirino Dela Cruz, along with PO1 Ariel Cantorna and two others, allegedly arrested Villarias under contentious circumstances.

Villarias testified that at around 8:00 p.m., he was awakened by police officers who, without explanation, frisked and handcuffed him.
He further stated the following:

SPO4 Dela Cruz brandished an armalite rifle while interacting with him.
Villarias was forcibly taken to a patrol vehicle and handcuffed to its steering wheel.
Upon returning to his house, the officers removed several personal belongings including fighting cocks, air guns, bolos, and various valuables such as a wedding ring, necklace, coin bank, cash, and men’s cologne.

Villarias filed a Complaint-Affidavit with the National Police Commission (NAPOLCOM), alleging abuse of authority and theft by the officers.
The complaint detailed not only the manner of his arrest but also highlighted that the incident may have been instigated by a personal vendetta involving his neighbor, Ruby Carambas.
A witness, Eneceto Gargallano, testified to having seen four police officers, including those implicated, entering Villarias’s home and handling fighting cocks and air guns.

On January 12, 2010, the National Police Commission declared SPO4 Dela Cruz and PO2 Cantorna guilty of grave misconduct, dismissing Dela Cruz from service.
The CSC’s September 11, 2012 Decision dismissed Dela Cruz’s appeal on the ground that it was filed out of time, thereby affirming the NAPOLCOM ruling.
Additional motions for reconsideration by Dela Cruz were filed:

A motion before the NAPOLCOM was denied in a December 15, 2010 Resolution for having been untimely filed.
An appeal before the Civil Service Commission, asserting that the appeal period should be reckoned from the promulgation date rather than the receipt date, was also dismissed.

The Court of Appeals, in its June 27, 2014 Decision, upheld the prior rulings on two grounds:

Dela Cruz’s appeal filed beyond the allowable period.
There was no denial of due process since he had the opportunity to produce evidence of timely filing during his motion for reconsideration.

A subsequent November 18, 2014 Resolution by the Court of Appeals denied Dela Cruz’s motion for reconsideration.

The determination that his appeal was filed out of time, arguing that the period should start from the promulgation date (December 15, 2010) rather than the receipt date (allegedly January 4, 2011).
The sufficiency of the evidence used to establish his liability for grave misconduct.

Dela Cruz failed to produce documentary proof regarding the actual receipt date of the resolution.
The administrative and judicial findings, based on substantial evidence including witness testimonies, conclusively established his misconduct.

Whether the Court of Appeals erred in determining that SPO4 Dela Cruz’s appeal had been filed beyond the allowable period (i.e., out of time).

Whether the evidence presented by Villarias was sufficient to establish that Dela Cruz committed grave misconduct, including conducting an unlawful warrantless arrest and engaging in acts of theft and dishonesty.

Whether the appellate court should review questions of fact regarding the sufficiency of evidence in cases involving administrative misconduct.
The extent to which procedural rules may be relaxed in administrative cases and if such relaxation applies in the present instance.