Dadulo v. Court of Appeals
REITERATIONFacts
The Antecedents: On September 22, 2002, Gloria Patangui (Patangui) alleged that Rosario Dadulo (Dadulo), the Barangay Chairperson of Barangay Payatas A, Quezon City, along with several Barangay Security Development Officers (BSDOs), seized galvanized iron sheets and lumber from her backyard. Witnesses, including Patangui's daughter, observed the taking and identified Dadulo as the one giving the orders. The materials were subsequently discovered being used in the construction of a new barangay outpost. Dadulo defended her actions by claiming that the construction was illegal as it was being built on land owned by the National Waterworks and Sewerage Authority (NAWASA) and that she was merely inspecting the site. Procedural History: Patangui filed an administrative complaint with the Office of the Ombudsman. The Ombudsman found Dadulo and BSDO Edgar Saraga guilty of conduct prejudicial to the best interest of the service, imposing a six-month suspension. The Court of Appeals (CA) affirmed the Ombudsman's decision, ruling that substantial evidence existed to prove Dadulo ordered the seizure. Mayor Feliciano Belmonte, Jr. subsequently issued an order to implement the suspension. The Petition: Dadulo filed a petition for review on certiorari under Rule 45 of the Rules of Court. She argued that there was no substantial evidence to support the finding of guilt and that her actions were a legitimate exercise of her authority to prevent illegal construction on government property. She sought the reversal of the CA decision and the lifting of her suspension.
Issue(s)
Whether there is substantial evidence to show that petitioner ordered the seizure of Patangui's construction materials, thereby making her liable for conduct prejudicial to the best interest of the service.
Ruling
The petition is DENIED. The Decision of the Court of Appeals is AFFIRMED.
Ratio Decidendi
On the Issue of Substantial Evidence for Conduct Prejudicial to the Best Interest of the Service: The Court emphasized that administrative proceedings are governed by the substantial evidence rule, requiring only relevant evidence a reasonable mind might accept as adequate to support a conclusion. The Office of the Ombudsman's findings were supported by the testimony of the complainant's daughter and the physical evidence that the seized materials were utilized in the construction of a barangay outpost. Petitioner's defense of a sweeping general denial was deemed insufficient to overcome the positive and categorical assertions made by the respondent and her witnesses. Even if the construction materials were intended for an illegal structure on government land, their summary seizure by public officers without due process remains an administratively sanctionable act. The Supreme Court held that it is not its function to re-evaluate the credibility of witnesses or weigh conflicting evidence when the findings of the administrative agency are supported by the record and affirmed by the Court of Appeals.
Main Doctrine
Administrative proceedings are governed by the 'substantial evidence rule,' which defines substantial evidence as more than a mere scintilla but such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. Findings of fact by the Office of the Ombudsman are conclusive when supported by substantial evidence and are accorded due respect and weight, especially when affirmed by the Court of Appeals. Furthermore, the summary seizure of construction materials by public officers, even if intended to stop illegal construction, constitutes conduct prejudicial to the best interest of the service if done without legal process.