GR 174693; (August, 2007) (Digest)
G.R. No. 174693 ; August 31, 2007
CIVIL SERVICE COMMISSION, Petitioner, vs. DORINDA B. BUMOGAS, Respondent.
FACTS
Respondent Dorinda B. Bumogas was promoted to Municipal Treasurer of Peñarrubia, Abra. In her Personal Data Sheet, she indicated she was a college graduate from Abra Valley Colleges (AVC) with a Bachelor of Elementary Education (BEEd), attaching a transcript of records (TOR). The Civil Service Commission-Cordillera Administrative Region (CSC-CAR) received confidential information that her TOR was spurious. The Commission on Higher Education-CAR (CHED-CAR) informed the CSC that the Special Order (S.O.) number on her TOR, No. 2-100225, could not have been issued for a BEEd degree as their numbering starts with “211.” AVC later stated its records were destroyed by fire.
The CSC-CAR filed an administrative complaint for Dishonesty and Falsification of Public Document against Bumogas. She denied the charges, asserting she genuinely graduated from AVC, submitting her diploma and TOR, and claimed she had no participation in preparing the S.O. number. The CSC-CAR found her guilty and dismissed her from service, a decision affirmed by the CSC proper. The Court of Appeals reversed, dismissing the case for lack of merit.
ISSUE
Whether there is substantial evidence to prove respondent is administratively liable for dishonesty and falsification of public document.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic centers on the quantum of evidence required in administrative cases and the burden of proof. Administrative liability must be established by substantial evidence, or such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. The CSC’s case rested primarily on the CHED certification that the S.O. number format on the TOR was irregular. However, this alone did not constitute substantial evidence that Bumogas herself forged the document or knowingly used a falsified one.
The Court emphasized that the preparation and issuance of the TOR and its S.O. number were official acts of the educational institution, AVC. There was no direct evidence proving Bumogas participated in creating the allegedly spurious S.O. number. Possession and use of the document, without proof of personal fabrication or knowledge of its falsity, are insufficient to establish administrative guilt. The Court also noted the CSC had previously granted Bumogas a Professional Civil Service Eligibility, which logically presumed a review of her qualifications. Therefore, the petitioner failed to discharge its burden of proving the respondent’s culpability by substantial evidence.