The Supreme Court ruled that a person found liable for dishonesty and falsification of official documents is ineligible to hold public office and cannot initiate a quo warranto proceeding to claim a right to that office. This decision emphasizes the importance of integrity in public service and prevents individuals with a history of dishonesty from holding positions of authority. It also protects the public interest by ensuring that only qualified and trustworthy individuals hold public office, maintaining the integrity of government functions.

When a Falsified Degree Undermines a Claim to Public Office

This case revolves around a petition for certiorari filed by Lee T. Arroyo against the Court of Appeals (CA) and Ulysses A. Brito, challenging the CA’s decision to execute a prior ruling in a quo warranto case. The original quo warranto petition was filed by Brito, seeking to be reinstated to his former position as Regional Director of the National Commission on Indigenous Peoples (NCIP). Arroyo contested Brito’s claim, arguing that he was not qualified for the position due to falsification of his college degree. The Supreme Court ultimately sided with Arroyo, highlighting the critical impact of dishonesty on an individual’s eligibility to hold public office and initiate legal proceedings related to it.

The controversy began with the reorganization of the NCIP following the enactment of Republic Act No. 8371, also known as “The Indigenous Peoples’ Rights Act of 1997.” Brito, who was temporarily appointed as Regional Director for Region V, was later replaced by Arroyo. Subsequently, Brito filed a petition for quo warranto, asserting his right to security of tenure and questioning Arroyo’s qualifications. Arroyo countered that Brito’s appointment was temporary and that he lacked the necessary Career Executive Service (CES) eligibility. In its initial decision, the CA partially granted Brito’s petition, ordering his reinstatement. However, Arroyo moved for reconsideration, presenting evidence that Brito had falsified his bachelor’s degree, which is a requirement for the position.

Arroyo submitted a certified true copy of the Office of the President’s (OP) decision, which found Brito guilty of dishonesty and falsification of official documents, leading to his dismissal from government service. Despite this, the CA denied Arroyo’s motion for reconsideration and granted Brito’s motion for execution of the original quo warranto judgment. The CA reasoned that Brito had appealed the OP decision, but Arroyo challenged this, arguing that Brito failed to provide evidence of such an appeal. This led to the current petition before the Supreme Court, which was asked to determine whether the CA had gravely abused its discretion in directing the execution of its decision in favor of Brito.

The Supreme Court addressed whether the CA gravely abused its discretion in directing the execution of its judgment on the quo warranto petition. The Court acknowledged the general principle of the immutability of judgments, which dictates that final and executory judgments can no longer be reviewed or modified. However, it also recognized exceptions to this rule, including situations where circumstances transpire after the finality of the judgment that would render its execution unjust or inequitable. Arroyo invoked this exception, arguing that the OP’s decision finding Brito liable for dishonesty due to the falsified college degree constituted a supervening event that made the execution of the quo warranto judgment unjust.

The Court emphasized that for a supervening event to apply, it must be based on proven facts that alter the parties’ situation in a way that makes the execution of the judgment unfair. Here, the OP’s decision, which became final after the CA’s initial ruling and Arroyo’s failure to appeal, was deemed such a supervening event. The decision established that Brito had falsified his bachelor’s degree, which is a fundamental requirement for admission into the career service and for holding a position within the Career Executive Service (CES). The court quoted the factual findings of the Presidential Anti-Graft Commission (PAGC), affirmed by the OP, which revealed that Brito never obtained a diploma from Naga College Foundation (NCF) and that his Special Order was unauthorized.

In the present case, the registrar, Josefina P. Villanueva of the [NCF], has declared that [Brito] never obtained a diploma from their institution.

The Supreme Court also underscored the significance of Section 5, Rule 66 of the Rules of Court, which requires individuals initiating quo warranto proceedings to demonstrate their eligibility for the contested public office. Given Brito’s dishonesty and falsification of official documents, the Court found that he was ineligible for admission into the career service. This disqualification meant that he could not claim a better right to the Regional Director position through a quo warranto proceeding. Consequently, the CA was deemed to have gravely abused its discretion in directing the execution of its judgment, as it would result in a violation of civil service laws and be contrary to the interests of justice.

The Court also addressed the CA’s finding that Brito had appealed the OP decision, noting that Arroyo had submitted certified true copies of the OP’s decision and order confirming its finality. The Court pointed out that Brito failed to present any direct evidence to support his claim of an existing appeal. He could have easily submitted a copy of his petition for review to the CA, but he did not. Lacking any proof, the CA’s independent verification of the appeal was deemed arbitrary and insufficient to overcome the evidence presented by Arroyo. The Court emphasized that allegations alone are not evidence and that the burden of proof lies with the party asserting the affirmative of an issue.

Given Brito’s lack of eligibility and the final judgment against him, the Court determined that the CA had indeed gravely abused its discretion. This abuse was based not only on errors of jurisdiction but also on a gross misapprehension of facts. The Court found that the dismissal of Brito from government service and his disqualification from reemployment rendered the execution of the CA’s quo warranto judgment impossible, inequitable, and unjust. To provide a complete resolution, the Court also addressed the potential implications if Brito had been reinstated to the Regional Director position pending the resolution of the case.

The Court invoked the de facto officer doctrine, which validates the actions of an officer exercising authority under a color of appointment or election, even if that appointment is later found to be defective. The doctrine is intended to protect those who rely on the official acts of public officials by ensuring the functioning of the government despite technical defects in an official’s title to office. The elements of the de facto officer doctrine were further discussed: (1) there must be a de jure office; (2) there must be a color of right or general acquiescence by the public; and (3) there must be actual physical possession of the office in good faith.

The Court applied the de facto officer doctrine to the actions of Brito as Regional Director, stating that he had a colorable title to the position by virtue of the CA’s initial decision, even though he was ultimately found ineligible. It was emphasized that Brito’s ineligibility was unknown to the public at the time, and therefore, his official acts during his tenure were deemed valid. Nonetheless, the Court clarified that Brito did not possess the Regional Director position in good faith, given his awareness of his fabricated academic degree. This absence of good faith disqualified him from retaining the salaries and emoluments he received during his time as a de facto officer. The Court concluded that he must account for these amounts to the rightful officer, Arroyo.

FAQs

What was the key issue in this case?	The key issue was whether the Court of Appeals gravely abused its discretion in directing the execution of a judgment in a quo warranto petition, given that the petitioner was later found liable for dishonesty and falsification of official documents.
What is a quo warranto proceeding?	A quo warranto proceeding is a legal action to determine whether a person has the right to hold a public office or position. It is used to challenge the validity of someone’s claim to an office.
What is the de facto officer doctrine?	The de facto officer doctrine validates the actions of a person who holds a public office under a color of authority, even if their appointment is later found to be defective. This doctrine protects the public who rely on the official acts of those in apparent authority.
What was the supervening event in this case?	The supervening event was the Office of the President’s decision finding Ulysses A. Brito liable for dishonesty and falsification of official documents, which made him ineligible for the Regional Director position after the initial quo warranto judgment.
Why was Brito deemed ineligible for the Regional Director position?	Brito was deemed ineligible because he falsified his bachelor’s degree, which is a requirement for admission into the career service and for holding a position within the Career Executive Service (CES).
What happens to the salaries Brito received as a de facto officer?	Since Brito did not possess the Regional Director position in good faith due to his falsification, he is not allowed to retain the salaries and emoluments he received. He must account for these amounts to the rightful officer, Lee T. Arroyo.
What did the Supreme Court ultimately decide?	The Supreme Court granted the petition, modified the Court of Appeals’ decision to direct the dismissal of the quo warranto petition against Arroyo, and nullified the resolutions directing the execution of the quo warranto judgment.
What is the significance of Section 5, Rule 66 of the Rules of Court?	This section requires individuals initiating quo warranto proceedings to demonstrate their eligibility for the contested public office. Without such eligibility, the action may be dismissed at any stage.

In conclusion, the Supreme Court’s decision underscores the vital role of honesty and integrity in public service. By invalidating the CA’s decision and emphasizing the disqualification of individuals found guilty of dishonesty, the Court reinforced the necessity of maintaining high ethical standards in government. The ruling also clarifies the application of the de facto officer doctrine, ensuring that while official actions may be validated, individuals who obtained their positions through dishonesty cannot benefit from their wrongful tenure.

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: LEE T. ARROYO v. COURT OF APPEALS and ULYSSES A. BRITO, G.R. No. 202860, April 10, 2019