Case Digest (G.R. No. 198994)
Facts:
In Department of Health v. Priscilla G. Camposano, Enrique L. Perez, and Imelda Q. Agustin (496 Phil. 886, April 27, 2005), the Department of Health–National Capital Region (DOH-NCR), petitioner, challenged the dismissal of respondents Priscilla G. Camposano (Finance and Management Officer II), Imelda Q. Agustin (Accountant I), and Enrique L. Perez (Acting Supply Officer III). On May 15, 1996, a complaint was filed with the DOH Resident Ombudsman concerning the alleged anomalous purchase of 1,500 bottles of Ferrous Sulfate capsules worth ₱330,000.00. The Resident Ombudsman’s August 6, 1996 report recommended formal charges of Dishonesty and Grave Misconduct; on August 8, 1996 the Secretary of Health accordingly filed administrative charges. By Administrative Order No. 298 (October 25, 1996), President Ramos created an ad hoc committee—composed of members of the Presidential Commission Against Graft and Corruption (PCAGC)—to conduct the inquiry under Sections 38–40 of PD 807. AftCase Digest (G.R. No. 198994)
Facts:
- Employment and Complaint
- Respondents Priscilla B. Camposano (Finance and Management Officer II), Imelda Q. Agustin (Accountant I), and Enrique L. Perez (Acting Supply Officer III) were employees of the Department of Health–National Capital Region (DOH-NCR).
- On May 15, 1996, concerned DOH-NCR employees filed a complaint with the Resident Ombudsman alleging an anomalous purchase of 1,500 bottles of Ferrous Sulfate capsules worth ₱330,000.
- Investigation and Administrative Orders
- On August 6, 1996, the Resident Ombudsman recommended formal charges of grave misconduct, dishonesty, and violation of RA 3019. On August 8, 1996, the Secretary of Health filed these charges.
- By Administrative Order No. 298 (October 25, 1996), President Ramos created an Ad Hoc Committee (composed of PCAGC members) to investigate under PD 807. On January 23, 1998, the PCAGC found the respondents guilty and recommended dismissal. On April 20, 1998 (AO 390), President Ramos dismissed Dir. Majarais and remanded respondents’ records to the Health Secretary “for appropriate action.”
- Procedural History
- On May 8, 1998, Secretary Carmencita N. Reodica dismissed respondents by adopting the PCAGC resolution. On June 5, 1998, she denied their motion for reconsideration.
- Respondents appealed to the Civil Service Commission (CSC), which denied their appeal (May 21, 1999) and reconsideration (September 30, 1999). Horacio Cabrera’s separate appeal succeeded at the Court of Appeals (October 15, 2001).
- Respondents’ own petition to the CA (CA-GR SP No. 67720) was granted in a March 19, 2003 decision setting aside the CSC resolutions and ordering reinstatement with back pay. The DOH petitioned the Supreme Court under Rule 45.
Issues:
- Jurisdiction
- Did the Presidential Commission Against Graft and Corruption (PCAGC) lack jurisdiction to investigate non-presidential appointees?
- Delegation and Decision-Making
- Did the Secretary of Health relinquish her authority and act mechanically by merely adopting the PCAGC findings without independent assessment?
- Sufficiency of Investigation
- Did the Court of Appeals err in disregarding the exhaustive PCAGC investigation and its findings on the illegal purchase contract?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)