Facts:

The case involves Quirino T. Dela Cruz (petitioner) and the National Police Commission (respondent). The events leading to the case began on October 13, 2001, when Sonny H. Villarias was arrested by four police officers, including SPO4 Quirino Dela Cruz and PO1 Ariel Cantorna, for allegedly possessing firearms without permits. Villarias claimed that the arrest was unlawful, as he was not committing any offense at the time. He filed a Complaint-Affidavit against the officers on August 15, 2002, alleging that they had unlawfully entered his home, assaulted him, and stolen various personal belongings, including cash and valuable items. The National Police Commission subsequently filed a complaint against Dela Cruz and Cantorna, charging them with grave misconduct.

On July 23, 2009, the Regional Trial Court acquitted Villarias, stating that the arrest was unlawful and that the evidence obtained was inadmissible. However, on January 12, 2010, the National Police Commission foun...

Facts:

Background of the Case

• Petitioner Quirino T. Dela Cruz, a police officer, was dismissed from service for grave misconduct by the National Police Commission (NAPOLCOM) based on a complaint filed by Sonny H. Villarias.
• Villarias was arrested on October 13, 2001, by SPO4 Dela Cruz and other officers for allegedly possessing firearms without permits. Villarias claimed that the officers unlawfully entered his home, arrested him without cause, and stole his valuables, including fighting cocks, jewelry, and cash.

Villarias’ Allegations

• Villarias alleged that SPO4 Dela Cruz and other officers entered his home without a warrant, handcuffed him, and stole his belongings. He also claimed that the officers forced him to admit ownership of two defective handguns.
• Villarias believed the arrest was orchestrated by his neighbor, Ruby Carambas, who had a personal grudge against him.

Administrative and Criminal Proceedings

• Villarias filed a complaint with NAPOLCOM, which found SPO4 Dela Cruz and PO2 Cantorna guilty of grave misconduct and dismissed them from service.
• In a separate criminal case, the Regional Trial Court acquitted Villarias, finding that his arrest was unlawful and that the evidence against him was inadmissible.

Appeals and Motions

• SPO4 Dela Cruz filed a Motion for Reconsideration with NAPOLCOM, which was denied. He then appealed to the Civil Service Commission (CSC), but his appeal was dismissed for being filed out of time.
• The Court of Appeals affirmed the CSC’s decision, ruling that SPO4 Dela Cruz failed to prove that his appeal was timely filed.

Issue:

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Ruling:

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Ratio:

1. Timeliness of Appeal: The Court emphasized that procedural rules must be strictly followed. SPO4 Dela Cruz failed to provide evidence that he received the NAPOLCOM Resolution on January 4, 2011, as he claimed. Without proof, the Court could not relax the rules to accommodate his late appeal.
2. Sufficiency of Evidence: The Court upheld the factual findings of NAPOLCOM, CSC, and the Court of Appeals, which found that SPO4 Dela Cruz committed grave misconduct. The testimonies of Villarias, his common-law wife, and a witness, along with the Regional Trial Court’s findings, constituted substantial evidence to support the dismissal.
3. Relaxation of Procedural Rules: The Court reiterated that procedural rules may only be relaxed in compelling and justifiable circumstances. SPO4 Dela Cruz failed to demonstrate such circumstances, and his actions as a police officer warranted strict accountability.

Conclusion:

The Supreme Court affirmed the dismissal of SPO4 Dela Cruz from service, finding no merit in his claims of procedural errors or insufficient evidence. The Court emphasized the importance of upholding the law and ensuring accountability for police officers who abuse their authority.