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Digest: Gubatanga v. Bodoy (790 SCRA 205, 2016)

Digest: Gubatanga v. Bodoy (790 SCRA 205, 2016)


Facts:  The case stemmed from the Affidavit Complain filed by COC Gubatanga charging Bodoy with grave misconduct and falsification of commercial document for unauthorized withdrawal in the amount of Php60,000.00 on 19 March 2008.


1. Whether or not Bodoy is guilty of grave misconduct but of dishonesty

2. Whether or not administrative proceeding will proceed even before if there is judgement in criminal complaint.



  1. Yes. It is without doubt that Bodoy is guilty of dishonesty.

This Court will not tolerate dishonesty. Persons involved in the dispensation of justice, from the highest official to the lowest employee, must live up to the strictest standards of integrity, probity, uprightness and diligence in the public service. As the assumption of public office is impressed with paramount public interest, which requires the highest standards of ethical standards, persons aspiring for public office must observe honesty, candor and faithful compliance with the law. It has been consistently stressed that even minor employees mirror the image of the courts they serve; thus, they are required to preserve the judiciary's good name and standing as a true temple of justice.

Dishonesty is a serious offense which reflects a person's character and exposes the moral decay which virtually destroys his honor, virtue and integrity. It is a malevolent act that has no place in the judiciary, as no other office in the government service exacts a greater demand for moral righteousness from an employee than a position in the judiciary

  1. Yes. the instant administrative complaint can proceed even before there is judgment in the criminal case involving the same matter. In administrative proceedings, such as this case, the quantum of proof required to establish the administrative liability of respondent is substantial evidence, not proof beyond reasonable doubt. Substantial evidence means such relevant evidence as reasonable mind might accept as adequate to support a conclusion.

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