G.R. No. L-28274 - IN RE: Padilla vs. Republic

Petitioner: Rodomiel J. Domingo, Barangay Chairman of Barangay 686, Zone 75, District V, Manila.
Respondents: SK officials Kathryn Joy Paguio, Allan Jay M. Esguerra, and Neil Patrick H. Celis.

A complaint-affidavit was filed by the respondents before the Office of the Ombudsman (OMB).
The allegations included charges of malversation, falsification of public document, dishonesty, and grave misconduct.
The specific allegation centered on the misappropriation of a cash advance amounting to ₱16,784.00 taken from the SK funds in 2002.
Additional allegation involved the submission of a false statement in the form of a Justification for the 2003 Barangay Budget and Expenditures, wherein petitioner declared that no incumbent SK officials existed—a claim contrary to the fact that the respondents were duly elected and actively serving as SK officials.

Audit Observation Memorandum issued by the Office of the City Auditor of Manila dated 9 February 2004.
A photocopy of the certified true copy of the Justification allegedly containing a false declaration.
Certificate of canvass of voters and the proclamation of winning candidates for the SK Chairmanship and council positions from the SK election on 15 July 2002.
Affidavits of Esguerra, Danilo Baldivia, and Paolo Tagabe affirming that their services (painting the barangay sidewalk) were hired by respondent Paguio.

Denial of the allegations with an assertion that all financial transactions were properly documented and liquidated.
Explanation that the check covering the ₱16,784.00 was properly liquidated, supported by pertinent documents as of 26 June 2003.
In his reply-affidavit, petitioner questioned the authenticity of the Justification, asserting that his signature therein was forged.

The OMB rendered judgment finding petitioner guilty of violating Section 4(b) of Republic Act No. 6713 (which mandates public officials to exercise the highest degree of professionalism), and imposed a penalty of six (6) months suspension from office.
The OMB dismissed further charges of misappropriation (deemed premature pending the audit outcome) and falsification of public document (on the basis that determining authenticity required judicial intervention).
Petitioner’s motion for reconsideration before the OMB was denied.
Petitioner then filed a petition for review with the Court of Appeals, which was denied, leading him to elevate the case to the Supreme Court.

Petitioner contended that he could not be held administratively liable for acts beyond his control and knowledge under RA No. 6713, especially asserting that he could not have falsified his own signature.
He argued that if he had been responsible for including the Justification, he could have affixed his genuine signature instead of a falsified one.
Additionally, petitioner emphasized that document submission, particularly for the barangay budget, was managed by others such as the Barangay Secretary or Treasurer, over whom he had no direct control.
He also maintained that the imposed six-month suspension was excessive since the alleged omissions did not result in any undue injury to the public service or to the respondents.

The OMB maintained that as the Chief Executive Officer of the barangay, petitioner was responsible for the propriety of all documents submitted to the Manila Barangay Bureau (MBB).
It underscored that the submission of a falsified Justification, regardless of questions about its authenticity, violated the conduct required of public officials—namely, honesty and integrity.
The penalty was defended as being in accordance with the provisions of RA No. 6713.

Whether petitioner can be held administratively liable for the submission of a document (the Justification) that he later repudiated by challenging the authenticity of his signature.
Whether the OMB’s finding of a violation of Section 4(b) of RA No. 6713 against petitioner is supported by substantial and conclusive evidence.
Whether the imposition of a six (6)-month suspension, in view of the alleged irregularity in the submission of the document, constitutes an excessive penalty under the principles of administrative discipline.
Whether the due process requirements were observed in charging petitioner, considering that the initial complaint-affidavit did not clearly indicate violation of Section 4(b) but rather included a broader set of allegations (malversation, falsification, dishonesty, and grave misconduct).
Whether it is proper for an administrative agency to hold petitioner liable for the so-called falsification without a judicial determination on the authenticity of his signature.