Case Digest (G.R. No. 188066)
Facts:
Office of the Ombudsman, Petitioner, vs. Cynthia E. Caberoy, Respondent, G.R. No. 188066, October 22, 2014, Supreme Court Third Division, Reyes, J., writing for the Court.Cynthia E. Caberoy was the Principal II of Ramon Avancena National High School (RANHS), Arevalo, Iloilo City. Angeles O. Tuares, a teacher at RANHS, filed Administrative Case OMB‑V‑A‑03‑0239‑E charging Caberoy with Oppression and with violations of Sections 3(e) and 3(f) of R.A. No. 3019 (Anti‑Graft and Corrupt Practices Act) for allegedly causing the withholding of Tuares’ June 2002 salary. That complaint was consolidated with OMB‑V‑A‑03‑0572‑I (complaints against other school officials).
The Office of the Ombudsman (Ombudsman‑Visayas) found Caberoy guilty only of Oppression and, in its Consolidated Decision dated June 30, 2005, imposed dismissal from service with cancellation of civil service eligibility, forfeiture of earned leave credits and retirement benefits, and disqualification from reemployment. Caberoy’s motion for reconsideration was denied by the Ombudsman on September 19, 2006.
Caberoy petitioned the Court of Appeals (CA) for certiorari relief. In its Decision dated November 21, 2008 (CA‑G.R. SP No. 03498), the CA reversed and set aside the Ombudsman’s Consolidated Decision and absolved Caberoy of any liability; its Resolution of May 14, 2009 denied reconsideration. The CA concluded that the records showed Tuares received her June 2002 salary (albeit in July), that Caberoy’s alleged “refusal” to release the salary was justified, and that the elements of undue injury, bad faith or discrimination required under Sections 3(e) and 3(f) of R.A. No. 3019 were absent; the CA also held that the acts did not constitute Oppression.
The Ombudsman filed a petition for review under Rule 45 of the Rules of Court seeking reversal of the CA’s decision, arguing (inter alia) that (a) the CA’s exoneration was contrary to the substantial evidence sustaining the Ombudsman’s findings; (b) Oppression is distinct from R.A. No. 3019 offenses and requires a different quantum of proof; (c) the payrolls and checks did not show Tuares’ name and Caberoy offered no proof that T...(Pro-only)
Issues:
- In a Rule 45 petition, may the Supreme Court review conflicting factual findings between the Court of Appeals and the Ombudsman?
- Was there substantial evidence to hold Cynthia E. Caberoy administratively liable for Oppression?
- Were the elements of violation of Sections 3(e) and 3(f), R.A. No. 3019...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)