Case Summary (G.R. No. 161425)
Factual Background
Rustom, under the guidance of his class adviser Epistola, along with classmates, was allegedly assigned to gather water lilies on March 12, 1999. The following day, despite being forbidden by his grandmother Maucencia, Rustom ventured to the river where he tragically drowned. Maucencia initiated a complaint against Epistola for reckless imprudence based on testimonies from other students, particularly Jhomel Patinio, who initially supported Maucencia's claims.
Revolving Statements and Complaints
The case saw a series of conflicting statements, primarily from Jhomel. He retracted his initial statement, indicating that only Harold Rafanan had been ordered to gather water lilies and that he felt pressured into retracting by respondents and other teachers. This led Maucencia to file an administrative complaint against Epistola and others for coercion and misrepresentation.
Findings of the Ombudsman
On June 7, 2001, the Office of the Deputy Ombudsman for Luzon found Epistola guilty of simple neglect of duty and grave misconduct along with Gamido for attempting to tamper with evidence related to Jhomel's affidavits. The Ombudsman imposed penalties of suspension totaling one month for Epistola and one year for Gamido, determining that their actions contributed to Rustom's death.
Court of Appeals Decision
On December 16, 2003, the Court of Appeals reversed the Ombudsman's decision, relying more heavily on Harold's affidavits and suggesting that Rustom intended to swim rather than collect lilies, thus attributing less liability to the respondents. The court also ruled that the Ombudsman lacked authority due to the filing of the complaint more than a year after the incident.
Legal Principles Applied
The Ombudsman contended that the principle of administrative liability could be substantiated through substantial evidence rather than merely by overwhelming proof. In their view, the actions of Gamido, particularly in administering oaths for affidavits related to the controversy, constituted grave misconduct.
Mootness and Academic Nature of the Case
Gamido's subsequent removal from his position as Barangay Captain rendered the petition moot and academic, as his suspension could no longer impact his tenure. The Supreme Court ruled that there was no justiciable controversy left to resolve, declining to impose any further penalties due to the absence of a current official status.
Conclusion on Legal Findings
The Supreme Court, nonethe
...continue readingCase Syllabus (G.R. No. 161425)
Case Overview
- This case involves a petition for review on certiorari filed by petitioners Aniano Desierto and Maucencia OrdoAez against respondents Ruth Epistola and Rodolfo Gamido.
- The petition assails the Decision dated December 16, 2003, by the Court of Appeals in CA-G.R. SP No. 68508, which reversed the findings of the Office of the Deputy Ombudsman for Luzon regarding the administrative liability of the respondents.
- The case arises from the drowning death of a Grade V student, Rustom OrdoAez, while gathering water lilies for a school project.
Background of the Case
- Rustom OrdoAez, a student at Bone North Elementary School, drowned while attempting to gather water lilies at a river on March 13, 1999.
- Rustom was ordered by his class adviser, Ruth Epistola, to collect lilies for beautification purposes on March 12, 1999.
- Despite being forbidden by his grandmother, Maucencia OrdoAez, Rustom sneaked out to the river where he ultimately drowned.
Initial Complaints and Investigations
- A criminal complaint was filed by Maucencia against Epistola for reckless imprudence following Rustom's death.
- Several affidavits were executed by classmates, including Jhomel Patinio, detailing the circumstances of Rustom's assignment and subsequent drowni