G.R. No. 188066 - Office of the Ombudsman vs. Caberoy

The case involves the Office of the Ombudsman (petitioner) and Cynthia E. Caberoy (respondent), principal of Ramon Avancena National High School (RANHS) in Arevalo, Iloilo City.
Caberoy faced administrative charges for Oppression and violations of Section 3(e) and (f) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act), specifically for allegedly withholding the salary of a teacher, Angeles O. Tuares, for the month of June 2002.

The case was initially docketed as OMB-V-A-03-0239-E and later consolidated with OMB-V-A-03-0572-I, which involved additional complaints against other educational officials.
In the Consolidated Decision issued on June 30, 2005 by the Ombudsman-Visayas, Caberoy was found guilty of Oppression and was penalized with dismissal from service, cancellation of civil service eligibility, forfeiture of earned leave credits and retirement benefits, and disqualification from reemployment in government service.
Caberoy filed a joint motion for reconsideration which was denied by the Ombudsman in an Order dated September 19, 2006.

The Ombudsman found that Angeles O. Tuares did not receive any salary in June 2002 because she failed to submit her clearance and Performance Appraisal Sheet for Teachers (PAST), unlike her colleagues who had complied with the required documents.
Payroll records and signatures indicated that Tuares eventually received her June 2002 salary on July 17 and July 25, 2002.
The Ombudsman also noted previous infractions committed by Caberoy, suggesting a pattern of misconduct in the handling of teachers’ salaries.

Caberoy petitioned for certiorari with the CA seeking reversal of her dismissal from service.
In its Decision dated November 21, 2008, the CA reversed and set aside the Ombudsman's Consolidated Decision, absolving Caberoy from any administrative liability.
The CA found that no undue injury was caused to Tuares because the payroll entries and subsequent disbursements proved that she was indeed paid, and that Caberoy’s action in withholding the salary was justified under the premise that required documents were not submitted.

The Ombudsman contended that the CA erred by basing its exoneration of Caberoy on the finding that Tuares eventually received her salary, arguing that there remained substantial evidence of Caberoy’s oppressive behavior and prior misconduct.
The petition for review under Rule 45 of the Rules of Court asserted that the reversal by the CA was an error of law because the Ombudsman’s decision was supported by substantial evidence and that the distinct quantum of proof required for administrative offenses (Oppression) should have been met.

Whether the findings of the Ombudsman, which determined Caberoy was guilty of Oppression based on the withholding of Tuares’ salary, were supported by substantial evidence.
Whether the payroll and documentary evidence proving Tuares eventually received her salary exonerated Caberoy as maintained by the CA.

Whether the consideration of the delay in releasing Tuares’ salary, due to her failure to submit required documents, legally constitutes an act of oppression or grave abuse of authority.
Whether the CA properly distinguished between the administrative charge of Oppression and the alleged violations under R.A. No. 3019 with regard to the element of undue injury.

Whether the CA committed a reversible error by overturning the Ombudsman’s findings despite the latter’s claim of substantial evidence supporting Caberoy’s misconduct.
Whether the differences in the required quantum of proof for Oppression versus the violation of R.A. No. 3019 were properly applied in reversing the administrative findings.