Ombudsman v. Lazaro-Baldazo
REITERATIONFacts
The Antecedents: Ricardo Gonzaga filed an administrative complaint against Priscilla Lazaro-Baldazo, the Municipal Civil Registrar of Bustos, Bulacan, for alleged falsification of a Deed of Donation dated September 18, 1995, and Teofista Lazaro-Gonzaga's Death Certificate. Ricardo alleged that Baldazo, taking advantage of her position, falsified the Deed of Donation to make it appear that Teofista executed it when she was already incapable, and falsified the Death Certificate to indicate Teofista died in Bustos, Bulacan, when she actually died in Manila. Procedural History: Baldazo denied the accusations, claiming the Deed of Donation was taken by Ricardo after it was signed and undated, and that Ricardo himself falsified the Death Certificate. The Ombudsman found Baldazo guilty of dishonesty and recommended her dismissal. The Court of Appeals (CA) reversed the Ombudsman's decision, finding insufficient evidence. The Office of the Ombudsman's motion for reconsideration was denied, leading to the present petition for review on certiorari. The Petition: The Office of the Ombudsman seeks to nullify the CA's decision, arguing that the CA erroneously reversed the Ombudsman's finding of guilt, which was allegedly supported by overwhelming evidence.
Issue(s)
Whether the Court of Appeals erred in reversing the Ombudsman's decision finding respondent Baldazo guilty of dishonesty. Whether there was sufficient evidence to establish falsification of the Deed of Donation. Whether there was sufficient evidence to establish falsification of the Death Certificate.
Ruling
The petition is denied for lack of merit. The assailed Court of Appeals decision and resolution are affirmed in toto. The complaint against the respondent is ordered dismissed.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in reversing the Ombudsman's decision finding respondent Baldazo guilty of dishonesty: The Supreme Court held that the petition raises factual issues, which are generally not reviewable in a petition for review on certiorari under Rule 45. The Court found no grave reversible error committed by the CA in its factual review of the Ombudsman's decision. The burden of proof in administrative proceedings lies with the complainant, who must prove allegations by substantial evidence. In this case, the complainant failed to present clear and convincing evidence to contradict the presumption of regularity of the notarized Deed of Donation and the Death Certificate. Therefore, there was no basis for the Ombudsman to adjudge respondent Baldazo guilty of dishonesty, and consequently, no legal basis to recommend her dismissal from the service. On the issue of whether there was sufficient evidence to establish falsification of the Deed of Donation: The Court affirmed the CA's finding that the evidence was insufficient. The Deed of Donation was a public document, duly notarized, and thus enjoys the presumption of regularity and authenticity. To contradict this presumption, clear, convincing, and more than merely preponderant evidence is required. The records were bereft of such evidence to overcome the presumption in favor of the notarized deed. Therefore, the alleged falsification of the Deed of Donation was not sufficiently established. On the issue of whether there was sufficient evidence to establish falsification of the Death Certificate: Similar to the Deed of Donation, the Death Certificate is also a public document and enjoys the presumption of having been regularly issued. The complainant failed to present sufficient evidence to overcome this presumption. Without clear and convincing proof of falsification, the charge against Baldazo could not be sustained. Consequently, the Ombudsman's finding of guilt based on these unsubstantiated allegations was erroneous.
Main Doctrine
The Court of Appeals correctly reversed the Ombudsman's decision finding the respondent guilty of dishonesty due to falsification of public documents, as the complainant failed to present clear and convincing evidence to overcome the presumption of regularity accorded to notarized public documents.