The Supreme Court held that a public official cannot be sanctioned for violating the norms of conduct under Section 4(b) of Republic Act No. 6713, particularly if they were not properly charged with said violation. Additionally, the court found that the evidence presented did not sufficiently prove that the official was responsible for submitting a falsified document. This ruling underscores the importance of due process and the need for substantial evidence in administrative proceedings against public officials.

Unsigned Documents: Can a Barangay Chairman Be Held Liable?

This case revolves around an administrative complaint filed by Sangguniang Kabataan (SK) officials against Rodomiel J. Domingo, the Barangay Chairman of Barangay 686, Zone 75, District V, Manila. The SK officials alleged that Domingo, along with the Barangay Treasurer, engaged in malversation, falsification of public documents, dishonesty, and grave misconduct. These charges stemmed from the alleged misappropriation of SK funds and the submission of a falsified document—a “Justification” supporting the 2003 Barangay Budget, which falsely claimed the barangay had no incumbent SK officials. The central question before the Supreme Court was whether Domingo could be held administratively liable for violating Section 4(b) of Republic Act No. 6713 based on the evidence presented, especially considering the contested authenticity of the document and the lack of a direct charge related to that specific violation.

Domingo denied the allegations and questioned the authenticity of the “Justification,” claiming his signature was forged. The Office of the Ombudsman (OMB) dismissed the charges of misappropriation and falsification but found Domingo guilty of violating Section 4(b) of R.A. No. 6713, which pertains to the norms of conduct for public officials, specifically professionalism. The OMB argued that as the chief executive officer of the barangay, Domingo was responsible for the propriety of all documents submitted in support of the proposed budget. The Court of Appeals affirmed the OMB’s decision. The Supreme Court, however, disagreed, finding that the evidence did not establish Domingo’s culpability and that he was denied due process.

The Supreme Court emphasized that while it generally defers to the factual findings of the Ombudsman, exceptions exist when such findings are contradicted by the evidence on record. In this case, Domingo had consistently questioned the authenticity of the “Justification,” claiming his signature was forged. The OMB deferred ruling on the falsification issue, yet simultaneously held Domingo liable for submitting the same document. The Supreme Court deemed this illogical, stating that the OMB could not assume the document was falsified and then hold Domingo liable based on that assumption. There was not any substantial evidence that implicated Domingo and supported the charge.

Furthermore, the Court found it implausible that Domingo would submit a document contradicting other official documents he had signed. Specifically, Domingo had signed several documents, including the 2003 barangay budget, budget proposal, barangay development plan, and statement of income and expenditures, all of which recognized the existence of the SK and allocated funds for it. The sole evidence against Domingo was the undated “Justification,” which the Court considered a “stray and aberrant document.” The provision mandates that public officials perform their duties with the highest degree of excellence, professionalism, intelligence, and skill.

More crucially, the Court pointed out that Domingo was denied due process. The complaint-affidavit and the OMB’s Evaluation Report did not charge Domingo with violating Section 4(b) of R.A. No. 6713. Due process requires that an accused be informed of the nature and cause of the charge against them. The Supreme Court stated the charge against him should not have been made, finding that “failure to abide by the norms of conduct under Section 4(b) of R.A. No. 6713 is not one of them.”

The Supreme Court reversed the Court of Appeals’ decision and dismissed the charge against Domingo, underscoring the importance of due process and the need for substantial evidence in administrative cases against public officials. The decision emphasizes that public officials must be clearly informed of the charges against them and that administrative bodies must present sufficient evidence to prove culpability before imposing sanctions. This serves as a reminder that administrative penalties must be based on solid legal and factual grounds, ensuring fairness and protecting the rights of those in public service.

FAQs

What was the key issue in this case?	The key issue was whether Barangay Chairman Domingo could be held administratively liable for violating Section 4(b) of R.A. No. 6713 based on the submission of an allegedly falsified document, and whether his due process rights were violated.
What is Section 4(b) of R.A. No. 6713?	Section 4(b) of R.A. No. 6713 mandates that public officials and employees perform their duties with the highest degree of excellence, professionalism, intelligence, and skill. It essentially sets a standard of professional conduct for those in public service.
Why did the Supreme Court reverse the Court of Appeals’ decision?	The Supreme Court reversed the decision because the evidence against Domingo was insufficient, and he was denied due process. The Court stated that he was not properly charged under Section 4(b) of R.A. No. 6713 and the falsification of the document had not been proven.
What is the significance of due process in this case?	Due process ensures that an accused is informed of the charges against them and has an opportunity to defend themselves. In this case, Domingo was not directly charged with violating Section 4(b) of R.A. No. 6713, which the Court cited as a violation of his rights.
What evidence was presented against Domingo?	The primary evidence was an undated “Justification” document found in the barangay bureau’s records, which contained a statement that there were no incumbent SK officials. The authenticity of Domingo’s signature on this document was contested.
Did the Ombudsman find Domingo guilty of falsification?	No, the Ombudsman did not make a conclusive ruling on the falsification of the document, stating that it necessitated a judicial determination. However, the Ombudsman still held Domingo liable for submitting it.
What was the penalty imposed by the Ombudsman?	The Ombudsman initially imposed a penalty of suspension from office for a period of six (6) months. The Supreme Court, in its ruling, set aside the penalty along with the other sanctions.
What does this case imply for future administrative proceedings?	This case reinforces the need for clear charges, substantial evidence, and adherence to due process in administrative proceedings against public officials. It also emphasizes the importance of verifying the authenticity and context of documents before using them as evidence.

In conclusion, the Supreme Court’s decision in Domingo v. Office of the Ombudsman serves as a crucial reminder of the protections afforded to public officials in administrative proceedings. It reinforces the principles of due process, requiring clear charges and substantial evidence to support any sanctions. This case underscores the judiciary’s role in safeguarding individual rights against potential overreach by administrative bodies.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Rodomiel J. Domingo v. Office of the Ombudsman Kathryn Joy B. Pagui G.R. No. 176127, January 30, 2009