The Supreme Court affirmed the dismissal of Irene K. Nacu, an Enterprise Service Officer at the Philippine Economic Zone Authority (PEZA), finding substantial evidence of dishonesty, grave misconduct, and conduct prejudicial to the best interest of the service. This ruling underscores that administrative bodies’ findings, when supported by relevant evidence, are generally binding and final. It serves as a reminder of the high standard of conduct expected of public servants and the importance of adhering to administrative regulations.

Overtime Overreach: Can a Public Employee Feign Ignorance of Office Regulations?

This case originated from a complaint filed against Irene K. Nacu by Edison (Bataan) Cogeneration Corporation (EBCC), alleging that Nacu charged overtime fees despite a PEZA memorandum order prohibiting such charges. PEZA conducted a preliminary investigation, which led to the discovery of questionable Statements of Overtime Services (SOS) bearing Nacu’s signature. Subsequent investigation by the Philippine National Police Crime Laboratory (PNP Crime Lab) confirmed that Nacu had indeed signed some of the SOS forms, leading to a formal charge against her. Nacu denied the charges, claiming lack of awareness of the memorandum and questioning the validity of the evidence against her. This case hinges on whether substantial evidence supported PEZA’s decision to dismiss Nacu and whether she could claim ignorance of the regulations.

The legal framework for this case is rooted in the principles of administrative law, specifically the standard of substantial evidence required to support findings of administrative bodies. The Supreme Court has consistently held that substantial evidence means “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” This standard acknowledges the expertise of administrative agencies in their respective fields and respects their decisions when based on sound reasoning and credible evidence. The court emphasized that this standard is met “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,” as was stated in Marcelo v. Bungubung, G.R. No. 175201, April 23, 2008.

The Court examined the evidence presented against Nacu, including the PNP Crime Lab’s report, the testimonies of witnesses, and statements made during the preliminary investigation. While Nacu’s camp questioned the reliability of the PNP Crime Lab’s findings, particularly in light of the National Bureau of Investigation’s (NBI) initial assessment of the signature samples, the Court clarified that the PNP and NBI are separate agencies with independent findings. The Court also noted that Nacu failed to provide her own evidence to refute the findings, emphasizing that “whoever alleges forgery has the burden of proving the same by clear and convincing evidence,” according to Aznar Brothers Realty v. Court of Appeals, 384 Phil. 95, 112 (2000). Moreover, the Court highlighted the testimony of Margallo, Nacu’s co-employee, who identified Nacu’s signatures on the SOS, further bolstering the evidence against her. This testimony was deemed credible because, as the Court stated, “Anyone who is familiar with a person’s writing from having seen him write… may give his opinion as to the genuineness of that person’s purported signature when it becomes material in the case.”

Addressing Nacu’s claim that she was unaware of the memorandum prohibiting overtime fees, the Court found this argument unconvincing. The Court pointed to the fact that the memorandum had been in effect for over a year, making it unlikely that Nacu, as a PEZA employee, was not informed of its implementation. The Court further clarified that such internal regulations do not require publication to take effect, citing Tañada v. Hon. Tuvera, 230 Phil. 528 (1986), which states that “Interpretative regulations and those merely internal in nature, that is, regulating only the personnel of the administrative agency and not the public, need not be published.” The court concluded that even without formal notice, Nacu should have been aware of the prohibition against directly collecting payments from PEZA-registered enterprises, given prior office orders and circulars addressing the issue.

The Court also dismissed Nacu’s argument that she was denied due process because statements were admitted without being made under oath and because Ligan was not presented as a witness. The Court reiterated that administrative proceedings are not strictly bound by technical rules of procedure and evidence. As the Court stated in Donato, Jr. v. Civil Service Commission Regional Office No. 1, G.R. No. 165788, February 7, 2007, “due process is satisfied when the parties are afforded fair and reasonable opportunity to explain their side of the controversy or given opportunity to move for a reconsideration of the action or ruling complained of.” The Court found that Nacu was given such an opportunity and that the proceedings were fair.

This case serves as a reminder that administrative bodies’ findings, when supported by substantial evidence, are generally binding and final. The Supreme Court recognized the principle by stating, “where the findings of the administrative body are amply supported by substantial evidence, such findings are accorded not only respect but also finality, and are binding on this Court.”

FAQs

What was the key issue in this case?	The key issue was whether there was substantial evidence to support the administrative body’s finding that Irene Nacu was guilty of dishonesty, grave misconduct, and conduct prejudicial to the best interest of the service, warranting her dismissal.
What is the standard of proof in administrative cases?	The standard of proof in administrative cases is substantial evidence, which means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. It does not require overwhelming or preponderant evidence but reasonable grounds for the conclusion.
Did the Court find the PNP Crime Lab report to be reliable?	Yes, the Court found the PNP Crime Lab report to be reliable, stating that the NBI’s opinion of insufficiency should not bear on the PNP Crime Lab’s own findings of the signatures.
Was Nacu’s claim of not knowing about the PEZA memorandum order accepted by the Court?	No, the Court rejected Nacu’s claim, reasoning that it was unlikely she was unaware of the memorandum given its duration and her position within PEZA. The Court found it difficult to believe that Nacu, one of the employees of PEZA affected by the memorandum order, was not in any way informed, whether by posting or personal notice, of the implementation of the said order.
Was Nacu denied due process in the administrative proceedings?	No, the Court found that Nacu was afforded due process as she was given a fair and reasonable opportunity to explain her side and present evidence. The administrative proceedings are not strictly bound by technical rules of procedure and evidence.
What is the significance of Memorandum Order No. 99-003 in this case?	Memorandum Order No. 99-003 prohibited PEZA employees from charging and collecting overtime fees from PEZA-registered enterprises, a regulation Nacu was found to have violated. This order was pivotal in establishing the basis for the charges against Nacu.
Can an ordinary witness testify on the genuineness of a signature?	Yes, the Court affirmed that an ordinary witness may testify on a signature if they are familiar with the person’s handwriting from having seen them write or handled documents signed by them. Margallo, Nacu’s co-employee, testified and identified that the signatures found on the questioned documents were indeed hers.
What was the final ruling of the Supreme Court?	The Supreme Court denied Nacu’s petition and affirmed the Court of Appeals’ decision, upholding her dismissal from PEZA. The SC stressed that Nacu was rightly found guilty of grave misconduct, dishonesty, and conduct prejudicial to the best interest of the service, and penalized with dismissal from the service and its accessory penalties.

This case reinforces the importance of ethical conduct and adherence to regulations within government service. Public employees are expected to uphold the integrity of their positions, and violations of established rules can lead to severe consequences, as demonstrated in Nacu’s dismissal. The ruling serves as a reminder to all public servants to maintain a high standard of professional behavior and to stay informed of the regulations governing their conduct.

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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: Irene K. Nacu vs. Civil Service Commission and Philippine Economic Zone Authority, G.R. No. 187752, November 23, 2010