G.R. No. 222469 - Villa-Ignacio vs. Barreras-Sulit

Dennis M. Villa-Ignacio (petitioner) was the Special Prosecutor at the Office of the Special Prosecutor (OSP), under the Office of the Ombudsman (OMB) in 2008.
Wendell E. Barreras-Sulit (respondent) was the Acting Deputy Special Prosecutor and Officer-in-Charge of the Administrative Division of the OSP.

Anonymous complaint alleged petitioner failed to report to work on various dates and left early, citing security logbook entries as evidence.
Investigation by Deputy Ombudsman Gerard A. Mosquera resulted in dismissal of this complaint due to insufficiency and unreliability of logbook entries; recognition that petitioner’s duties sometimes required working outside the office.

Assistant Special Prosecutor Rabendranath T. Uy charged petitioner with dishonesty, falsification of public documents, estafa, and violation of Section 3(e) of RA No. 3019 for habitual unauthorized absences and submission of falsified Certificates of Service (Jan–July 2008).
IAB dismissed these charges citing lack of probable cause, unreliability of the logbooks as evidence, and absence of criminal intent given petitioner’s admission of working outside office due to hostile environment.

Respondent filed charges against petitioner for similar offenses covering August–December 2008, including violations of Articles 171 and 174 of the Revised Penal Code (falsification), serious dishonesty, grave misconduct, conduct prejudicial to service, habitual absenteeism, and violation of RA 3019 Sec. 3(e).
Respondent alleged petitioner falsified Certificates of Service indicating full-time service except for 36 approved leave days when he was actually absent for 64 days, including 28 unauthorized.
Evidence included the certificates, leave applications, medical certifications, security guards’ Information Report on petitioner’s ingress and egress, and affidavit attesting to the report’s veracity.

Petitioner received an IAB Order (Nov. 24, 2009) directing him to file counter-affidavit; he claimed irregular and unfair service and questioned jurisdiction and authority of IAB Chairperson Orlando C. Casimiro.
Petitioner and his daughter filed a joint counter-affidavit denying allegations and asserting certificates of service were accurate. Cited hostile work environment causing him to work at home.
Respondent opposed petitioner’s arguments; maintained Ombudsman’s jurisdiction, reliability of security logbook, and lawfulness of IAB procedures.

IAB Decision (April 30, 2010) found petitioner guilty of dishonesty, grave misconduct, conduct prejudicial to service, and habitual absenteeism, ordering dismissal from the service.
IAB ruled no irregularity in notice or service; rejected petitioner’s challenge to Casimiro’s authority and affirmed jurisdiction of Ombudsman over OSP and petitioner.
Petitioner’s motion for reconsideration denied (Aug. 18, 2010).

Petitioner filed Petition for Review, questioning IAB's jurisdiction, authority of Casimiro, procedural irregularities, and falsification charges based on security logbooks.
CA Decision (Feb. 4, 2014) affirmed IAB findings, ruling Ombudsman possessed concurrent power with the President to remove Special Prosecutor, and petitioner guilty of serious dishonesty for falsifying Certificates of Service.
CA denied petitioner’s motion for reconsideration (Jan. 13, 2016).

Petitioner alleged harassment and conspiracy by Ombudsman Merceditas Gutierrez and cohorts to force his resignation through baseless complaints.
Maintained Ombudsman lacks authority to remove Special Prosecutor, exclusive to President.
Contended certificates of service were accurate with admitted work performed at home; security logbook unreliable.
Respondent upheld validity of CA and IAB decisions.

Whether the Office of the Ombudsman has disciplinary power over the Special Prosecutor.
Whether petitioner was denied due process in the administrative proceedings before the Internal Affairs Board.
Whether petitioner is administratively liable for alleged falsification of his Certificates of Service.