Case Summary (G.R. No. 225914)
Factual Antecedents
Muhad claimed to have been arrested at his store by police officers, specifically naming SPO2 Dante Naguera and several others in civilian clothing. He alleged that he was extorted for ₱200,000.00 for his release. His relatives, Diamungan Pangandaman and Mampao Rasul, corroborated his story, detailing how they were involved in the transaction that led to Muhad's release. Further statements indicated that Mendoza received a part of the extorted money. Mendoza denied these allegations, contending he had no knowledge of the arrest and was elsewhere at the time of the incident.
OMB Decision
The Office of the Ombudsman ruled against Mendoza and others, finding substantial evidence of grave misconduct based on consistent witness testimonies and evidence of financial transactions related to the extortion. Consequently, Mendoza was dismissed from service, with additional penalties applied.
CA Decision
Mendoza's appeal to the Court of Appeals resulted in a reversal of the Ombudsman's decision. The CA found insufficient substantial evidence to hold Mendoza liable, noting inconsistencies and a lack of corroboration regarding his participation in the alleged extortion. They highlighted omittance of key details in initial affidavits as suspicious and ruled that Mendoza ought not to have borne the burden of disproving his involvement in the absence of solid evidence against him.
Issues Raised
The Office of the Ombudsman contesting the CA’s ruling raised two issues: the existence of substantial evidence for Mendoza’s liability and the applicability of E.O. No. 226 concerning command responsibility in the context of administrative liability.
Arguments
The OMB reiterated that substantial evidence existed against Mendoza, primarily drawn from witness affidavits and claims of direct involvement in the extortion. Mendoza, in response, questioned the credibility of the OMB's reliance on these affidavits and asserted that the command responsibility doctrine under E.O. No. 226 was inapplicable since he was directly implicated in the extortion and not merely negligent in his supervisory duties.
The Court's Ruling
The Court granted the OMB's petition, establishing that Mendoza's dismissal for grave misconduct was justified based on substantial evidence provided by consistent testimonie
...continue readingCase Syllabus (G.R. No. 225914)
Case Overview
- This case involves a Petition for Review on Certiorari filed by the Office of the Ombudsman (OMB) against P/Supt. Crisostomo P. Mendoza.
- The petition seeks to reverse the decisions of the Court of Appeals (CA) which overturned the findings of the OMB regarding Mendoza's administrative liability for grave misconduct.
- The central issue revolves around Mendoza's alleged involvement in extorting money from Muhad Pangandaman y Makatanong (Muhad) in exchange for his release after an unlawful arrest.
Factual Antecedents
- Incident Details:
- On January 11, 2010, Muhad was arrested by police officers at his store in Quezon City.
- He was released after his relatives paid P200,000.00 as a bribe.
- Muhad's Allegations:
- He claimed that SPO2 Dante Naguera and other officers in civilian clothing arrested him and demanded money for his release.
- His relatives corroborated his account, stating they witnessed the arrest and the subsequent demand for payment.
- Additional Statements:
- A later affidavit indicated that Naguera handed a portion of the extorted money to Mendoza.
- Mendoza's Defense:
- Mendoza denied the accusations, asserting that he was not involved and provided an alibi, claiming he was attending religious services.
Office of the Ombudsman Decision
- Findings:
- The OMB found Mendoza guilty of grave misconduct based on substantial evidence, including the testimonies of Muhad and his relatives.
- The OMB concluded that there was a demand for money in exchange for Muhad's freedom, which implicated Mendoza.
- Penalties:
- Mendoza was dismissed from s