Case Summary (G.R. No. 181851)
Charges and Administrative Actions
Roquero was charged with grave misconduct on 1 October 1998, stemming from claims that he solicited sexual favors from Abutal in exchange for facilitating her employment. Following the charge, Roquero was preventively suspended for ninety days by Chancellor Perla D. Santos-Ocampo pending investigation. An Administrative Disciplinary Tribunal was convened to conduct the proceedings, initially represented by varying legal counsels for both sides.
Procedural Irregularities and Delays
Throughout the case, the prosecution significantly delayed submitting its formal offer of evidence, which it ultimately filed nearly five years after the complaint was initiated. The ADT, despite repeated requests from Roquero to dismiss the case due to the prosecution's failures, allowed the admission of evidence in June 2004, after having both ignored Roquero's prior motions and failing to act on critical procedural requests for an extended period.
Court of Appeals Rulings
Roquero appealed to the Court of Appeals seeking to annul the ADT's order denying his motion to dismiss the case. The Court of Appeals upheld the ADT's decision, ruling that the tribunal did not act with grave abuse of discretion, asserting that the failure of the prosecution to submit a formal offer of evidence did not merit case dismissal according to the applicable Uniform Rules on Administrative Cases in the Civil Service.
Constitutional Right to Speedy Disposition
The core issue presented before the Supreme Court was whether the ADT's prolonged inaction regarding Roquero’s motion for five years violated his constitutional right to a speedy disposition of cases as mandated by Section 16, Article III of the 1987 Philippine Constitution. The Supreme Court found merit in Roquero's petition, contending that the unreasonable delay constituted a violation of his rights.
Conclusion and Ruling
The Supreme Court reversed the prior decisions of the Court of Appeals and the ADT, emphasizing the sign
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Case Overview
- The case involves a petition for review on certiorari under Rule 45, filed by Capt. Wilfredo G. Roquero against several respondents including the Chancellor of UP-Manila and members of the Administrative Disciplinary Tribunal (ADT).
- The petition seeks to set aside the Decision dated March 22, 2007, and the Resolution dated February 1, 2008, from the Court of Appeals concerning CA-G.R. SP No. 87776.
- The administrative case originated from a complaint of Grave Misconduct filed by private respondent Imelda O. Abutal against Capt. Roquero, alleging misconduct during her application for a security position.
Facts of the Case
- Capt. Wilfredo G. Roquero is a Special Police Captain at the Philippine General Hospital, assigned to UP-Manila.
- Imelda O. Abutal, a Lady Guard applicant from Ex-Bataan Security Agency, filed a complaint against Roquero, claiming he proposed a sexual favor in exchange for facilitating her employment.
- A formal charge was filed on October 1, 1998, leading to Roquero's preventive suspension for 90 days.
- The ADT was established to hear the case, with various legal representatives involved throughout the proceedings.
Procedural History
- The ADT conducted hearings, but the prosecution failed to submit a formal offer o