Gonzales v. Domingo (G.R. No. 231756. August 14, 2017)


FACTS: Herein petitioners are employees of the Metropolitan Manila Development Authority (MMDA) and officers of the Kapisanan para sa Kagalingan ng mga Kawani ng MMDA (KKK-MMDA), a duly registered union of the rank-and-file employees of the MMDA. Respondents, on the other hand, are all officers of the MMDA.

The case stemmed from the MMDA's denial of the release of the incentive bonus allegedly due its rank-and-file employees pursuant to a Collective Negotiation Agreement (CNA) duly registered with the CSC on November 21, 2011. As a result thereof, some employees of the MMDA, including herein petitioners, assembled in front of its office on June 28, 2012, July 4, 2012, November 26, 2012, and December 3, 2012 to air their grievances. However, these concerted actions caused traffic and work disruption at the MMDA. Consequently, those who participated therein were administratively charged with Conduct Prejudicial to the Best Interest of the Service and were subsequently placed by the MMDA management on a 90- day preventive suspension without pay. Upon appeal, however, the CSC set aside the order of suspension and ordered the reinstatement and payment of back salaries of the concerned MMDA employees.

Armed with the belief that respondents caused their suspension and removal of their names from the payroll, petitioners filed an administrative Complaint for Grave Misconduct and Oppression against respondents. In their Joint Counter-Affidavit, respondents stated that the grant of the CNA incentive bonus is subject to the availability of funds out of the MMDA's unencumbered savings after the satisfaction of the agency's obligations at the end of the year. Unfortunately, for fiscal year 2011, the MMDA did not have such savings. In fact, the Department of Budget and Management (DBM) denied the allocation of funds for the grant of the CNA incentive bonus. Further, respondents maintained that they merely carried out the suspension and stop-payment of salary orders imposed on petitioners as a consequence of their illegal rallies in front of the MMDA office. As such, respondents claimed that they cannot be administratively charged for validly performing their official functions in good faith.

In its May 6, 2014 Decision, the CSC dismissed petitioners' complaint. The CSC found that the complaint is devoid of merit as petitioners failed to substantiate their claims of oppression and misconduct on the part of the respondents.

The CA affirmed the CSC's ruling.

ISSUE: The issue before this Court is whether or not the CA erred in affirming the CSC's finding that respondents did not commit grave misconduct or any act of oppression against petitioners.

HELD: The petition lacks merit. The petition is DENIED.
Misconduct, in the administrative sense, is a transgression of some established and definite rule of action. It is an intentional wrongdoing or a deliberate violation of a rule of law or standard of behavior, especially by a government official. Misconduct is considered grave if accompanied by corruption, a clear intent to violate the law, or a flagrant disregard of established rules. Oppression, on the other hand, which is also known as grave abuse of authority, is a misdemeanor committed by a public officer who, under color of his office, wrongfully inflicts upon any person any bodily harm, imprisonment or other injury. It is an act of cruelty, severity, or excessive use of authority. To be held administratively liable for Oppression or Grave Abuse of Authority, there must also be substantial evidence presented proving the complainant's allegations.

Substantial evidence is that amount of relevant evidence which a reasonable mind might accept as adequate to support a conclusion. The standard of substantial evidence is satisfied when there is reasonable ground to believe that a person is responsible for the misconduct complained of, even if such evidence might not be overwhelming or even preponderant.

In the instant case, the Court agreed with the CA that no substantial evidence was adduced to show the presence of the elements of corruption, a clear intent to violate the law or a flagrant disregard of established rules on the part of respondents when they carried out the suspension and stop-payment of salary orders imposed upon petitioners. By virtue of their official functions, respondents had to see to it that such orders are faithfully executed. There was no showing or proof that their acts were tinged with corruption, or wilful violation of the law or disregard of established rules. Thus, in the absence of sufficient evidence to the contrary, respondents are presumed to have regularly performed their duties and that they acted in good faith and with good motives.

Verily, there is no reason to overturn the ruling of the CA. Petitioners' insistence that the CA erred in affirming the CSC's finding that respondents did not commit grave misconduct or any act of oppression against petitioners is counterfactual. No rule is more entrenched in this jurisdiction than that the findings of fact of administrative bodies, if based on substantial evidence, are controlling on the reviewing authority. Stated in another manner, as a general rule, factual findings of administrative agencies, such as the CSC, that are affirmed by the CA, are conclusive and generally not reviewable by this Court. Administrative decisions on matters within their jurisdiction are entitled to respect and can only be set aside on proof of grave abuse of discretion, fraud or error of law. None of these defects has been shown in this case.

[1] Office of the Ombudsman v. Brillantes, G.R. No. 213699, September 28, 2016.
[2] Office of the Ombudsman v. Caberoy, G.R. No. 188066, October 22, 2014, 739 SCRA 118, 126.
[3] Donato, Jr. v. Civil Service Commission Regional Office No. 1, G.R. No. 165788, February 7, 2007, 515SCRA48, 59.
[4] Gonzales v. Civil Service Commission, G.R. No. 156253, June 15, 2006, 490 SCRA 741, 747.

Popular Posts