[ G.R. No. 205659. March 09, 2022 ]
PSI DARWIN D. VALDERAS, PETITIONER, VS. VILMA O. SULSE, RESPONDENT.
FACTS : The case stemmed from an alleged mauling incident on May 9, 2006, involving Vilma Sulse, then Secretary of the Sangguniang Bayan of Taft, Eastern Samar, and Mayor Francisco Adalim inside the Taft Police Station, where petitioner, Police Inspector Darwin Valderas, was the Chief of Police. Sulse claimed that while reporting a ransacking of her office, Mayor Adalim struck her several times as police officers failed to intervene, and Valderas refused to record the incident in the police blotter, instead detaining her upon the mayor’s orders. A medical exam conducted 43 days later showed minor injuries. Valderas denied negligence, asserting he arrived after the incident and that the blotter already contained an entry about a separate dispute involving Sulse. The Ombudsman initially found Valderas and other officers guilty of simple neglect of duty and suspended them for two months but later exonerated the others, maintaining Valderas’s guilt and reducing his suspension to one month for failing to record the alleged assault. On appeal, the Court of Appeals upheld the Ombudsman’s ruling, holding that even if no mauling occurred, Valderas should have recorded at least the altercation or rebuke by the mayor and vice mayor in the police blotter.
ISSUE : Whether or not the CA erred in affirming the Ombudsman's finding of Simple Neglect of Duty on the part of petitioner.
HELD: The Supreme Court acknowledged that the petitioner raised questions of fact, which are generally not reviewable under Rule 45 since the Court only addresses questions of law. However, it recognized exceptions when strict adherence to procedural rules would cause injustice. These exceptions include instances of speculative findings, misapprehension of facts, conflicting findings, or conclusions unsupported by evidence. The Court found that this case falls within such exceptions because the Court of Appeals’ conclusion—affirming the Ombudsman’s ruling—was based on speculation and misinterpretation of the facts, leading to an unreasonable and unfounded inference.
Public officers are expected to perform their duties with diligence, prudence, and care for the public’s benefit, and failure to do so can result in administrative liability for neglect of duty. Negligence refers to the lack of required diligence under specific circumstances. Neglect of duty may be gross—characterized by total indifference and flagrant disregard of duty—or simple, which involves carelessness or lack of attention to a task. Under the Civil Service Rules, simple neglect of duty is a less grave offense punishable by suspension of one month and one day to six months for the first offense, and dismissal for the second. In administrative cases, guilt must be proven by substantial evidence, meaning relevant and reasonable evidence sufficient to support a conclusion, though not necessarily overwhelming. The burden of proof lies with the complainant.
The Supreme Court ruled that the petitioner was not guilty of Simple Neglect of Duty. The Ombudsman and the Court of Appeals wrongly concluded that the petitioner should have recorded in the police blotter a disproved mauling incident or at least a verbal altercation involving Mayor Adalim and Vice Mayor Adel. The Court found these conclusions baseless, noting that there was no substantial evidence that the petitioner alone refused to record the incident, especially since all other officers present were exonerated. It clarified that a police blotter is meant only to record criminal incidents, arrests, and other significant reports—not every event or rebuke occurring in a police station. Since no mauling was proven and no duty was clearly neglected, the petitioner could not be held liable. Finally, while reaffirming the Ombudsman’s authority to discipline public officials, the Court reminded it to exercise prudence and fairness to avoid burdening public servants with unfounded cases that hinder government efficiency.
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