Case Summary (G.R. No. 201830)
Background of Administrative Complaints
In August 1991, the SPCWD’s Board of Directors dismissed division chiefs Evelyn Eje and Racquel Tolentino based on an administrative complaint initiated by Borja. Their dismissal was later contested and overturned by the Merit Systems Protection Board and subsequently by the CA, which ruled that their earlier dismissal was illegal. The CA mandated their reinstatement and backwages, but stated that such payments were Borja's personal liability, as he had acted outside the scope of his authority. This ruling attained finality in 1996, and the subsequent court orders confirmed Borja's obligation to reimburse SPCWD for the payments made to Eje and Tolentino's backwages.
Criminal and Administrative Proceedings Against Borja
Borja faced criminal charges for alleged violations of the Anti-Graft and Corrupt Practices Act related to the payments made to Eje and Tolentino. However, the Regional Trial Court dismissed these charges after concluding that the payments were made in good faith. In 2003, Borja and other SPCWD officers were administratively charged for using public funds to pay what were ultimately personal liabilities. Borja contended that the decision in the civil case could not inform administrative liability until the prescribed audit by the Commission on Audit (COA) was completed.
Ombudsman's Decision
In November 2007, the Ombudsman found Borja guilty of conduct prejudicial to the best interest of the service, imposing a one-year suspension without pay. The ruling emphasized that Borja disregarded evident liability despite prior rulings by the CA and COA regarding the personal nature of the payments due Eje and Tolentino. Borja's appeal to reconsider this decision was denied by the Ombudsman in 2009, leading to his pursuit of a petition for prohibition based on his belief that he was wrongly held administratively liable.
Court of Appeals Ruling
The CA reversed the Ombudsman's decision in October 2011, asserting that Borja acted in good faith, bolstered by findings from the COA that dismissed criminal liability for similar actions. This decision was based on the premise that if Borja was not criminally liable, he also should not bear administrative liability for the same actions carried out under the same conditions of good faith. The court held that without the presence of bad faith, the administrative complaints should not stand.
Supreme Court Proceedings and Ruling
The Ombudsman subsequently appealed to the Supreme Court, arguing that the dismissal of the criminal case did not absolve Borja from administrative liability. The court emphasized the distinction between criminal and administrative liabilities, indicating that different standards of proof apply—substantial evidence for administrative cases versus proof beyond a reasonable doubt for
...continue readingCase Syllabus (G.R. No. 201830)
Case Background
- The case involves consolidated petitions challenging the Court of Appeals (CA) Decision dated October 26, 2011, and Resolution dated May 9, 2012.
- These were in response to the Office of the Ombudsman’s (Ombudsman) findings against Roger F. Borja, who was found guilty of conduct prejudicial to the best interest of the service, resulting in a one-year suspension without pay.
- The Ombudsman’s original ruling stemmed from Borja’s actions concerning the financial liabilities associated with the wrongful dismissal of two employees, Evelyn Eje and Racquel Tolentino, from the San Pablo City Water District (SPCWD).
Factual Background
- In August 1991, the SPCWD Board of Directors dismissed Eje and Tolentino based on Borja’s administrative complaint.
- Their dismissals were later overturned by the CA, which awarded backwages and benefits but determined that Borja was personally liable for the payments, not SPCWD.
- The Regional Trial Court (RTC) ordered Borja to reimburse SPCWD for the payments, amounting to P1,942,031.82.
- Borja faced criminal charges for allegedly misusing public funds to pay Eje and Tolentino but was acquitted on the grounds of good faith as determined by the COA.
Ombudsman’s Ruling
- The Ombudsman concluded that Borja acted prejudicially to the service by using SPCWD funds to settle personal liabilities.
- Despite Borja's defense claiming the RTC ruling should not implicate him admin