CASE DIGEST : Zoleta v. Investigating Staff, Internal Affairs Board, Office of the Ombudsman G.R. No. 258888, April 8, 2024 Third Division — Gaerlan, J.

 

FACTS

Rolando B. Zoleta, an employee of the Office of the Ombudsman, was administratively charged with Grave Misconduct, Serious Dishonesty, and Conduct Prejudicial to the Best Interest of the Service. The complaint alleged that Zoleta was involved in fixing cases pending before the Office of the Ombudsman in exchange for money. The complaint was supported by, among others, screenshots of text messages and electronic communications allegedly exchanged between the complainant, Leonardo Nicolas, Jr., and a person identified in the messages as “AO Roy Zoleta.”

The screenshots contained communications concerning several cases pending before the Ombudsman. The complainant also submitted documents corresponding to the cases mentioned in the messages. The mobile phone number appearing in the electronic communications was compared with the mobile phone number indicated in Zoleta's Personal Data Sheet.

Zoleta denied the allegations and challenged the admissibility and probative value of the screenshots. He argued that the electronic communications were not properly authenticated under the Rules on Electronic Evidence. He likewise questioned the failure to present the persons who supposedly made or transmitted the messages for cross-examination.

The Office of the Ombudsman found Zoleta administratively liable and imposed the penalty of dismissal from service. The Court of Appeals affirmed the Ombudsman's ruling. Zoleta then elevated the matter to the Supreme Court, principally questioning the sufficiency and admissibility of the electronic evidence used against him.

ISSUE

Whether the screenshots of the text messages and electronic communications were admissible and sufficient to establish Zoleta's administrative liability despite the alleged failure to authenticate them under the Rules on Electronic Evidence.

HELD

The Supreme Court DENIED the petition and affirmed Zoleta's administrative liability.

The Court held that the technical rules of evidence, including the Rules on Electronic Evidence, are not strictly applied in administrative proceedings. Administrative bodies are not bound by the technical rules of procedure and evidence applicable in judicial proceedings. The applicable evidentiary standard is substantial evidence, or such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.

Accordingly, the failure to authenticate the screenshots in accordance with the formal requirements of the Rules on Electronic Evidence did not automatically render them without evidentiary value in the administrative proceedings. The Court considered the electronic communications together with the other evidence presented against Zoleta.

The Court found that the contents of the messages corresponded with actual cases pending before the Office of the Ombudsman. The messages were likewise corroborated by the testimony and affidavit of Nicolas, Jr., as well as by documents relating to the cases mentioned in the electronic communications.

The Court also considered the fact that the mobile phone number appearing in the messages was the same number reflected in Zoleta's Personal Data Sheet. This circumstance provided corroboration connecting Zoleta to the electronic communications.

The Court further held that the absence of cross-examination did not render the evidence inadmissible. Administrative proceedings do not require a trial-type proceeding in every instance, provided that the respondent is given a reasonable opportunity to explain and defend himself.

Considering the electronic communications together with the corroborating evidence, the Court found that the evidence against Zoleta constituted substantial evidence sufficient to support the administrative findings of Grave Misconduct, Serious Dishonesty, and Conduct Prejudicial to the Best Interest of the Service.