Digest: Wooden v. Civil Service Commission (471 SCRA 512, 2005)

Grounds which would warrant Reversal of Administrative Findings

Digest: Wooden v. Civil Service Commission (471 SCRA 512, 2005)

G.R. NO. 152884. September 30, 2005

AUSTRIA-MARTINEZ, J.:

 

Facts:  Sometime in the School Year 1990-1991, petitioner, who was then a fourth year student in Bachelor of Secondary Education (BSED) at Saint Louis University (SLU), applied for graduation. His application was approved subject to completion of a two-course, six-unit deficiency in the summer term of 1991 or by May 1991. Later, he was appointed as Staff Coordinator of "Louisian Educator '91", the annual of the College of Education, SLU

petitioner joined the graduation rites of the College of Education, SLU. Thereafter, he enrolled and completed his two-course, six-unit deficiency in the summer term of 1991 or by May 1991.  On June 11, 1991, he was employed as Substitute Teacher at the SLU Laboratory High School. He was a member of the teaching staff until the end of school year 1991-1992, or April 30, 1992

petitioner filed his application for the Professional Board Examinations for Teachers (PBET), stating therein that he graduated in March 1991. His application was approved on September 20, 1991

 

upon petitioner's application for his transcript of records, SLU informed him that a reevaluation of his scholastic records revealed that he needed to complete a three-unit English subject.

petitioner took the scheduled PBET. Subsequently, petitioner enrolled in SLU, under protest, and completed the three-unit subject deficiency in the second semester of school year 1991-1992.

On June 8, 1992, the results of the PBET were released. Petitioner passed the PBET with a rating of 76.38%

petitioner submitted his duly accomplished Personal Data Sheet (PDS) in connection with his appointment as Teacher I of Guinzadan National High School, Bauko, Mountain Province. He indicated in Item No. 17 of the PDS that he finished his BSED from SLU with inclusive dates of attendance from 1987 to 1991; and in Item No. 18, he indicated the PBET date of examination as 1992

 

On September 25, 1997, the CSC - Cordillera Administrative Region filed against petitioner a Formal Charge for Dishonesty and Falsification, docketed as Adm. Case No. 97-69

 

petitioner was declared guilty of dishonesty thru falsification of public document and dismissed from service with the accessory penalties thereof. 

Issue: whether or not factual finding of an administrative agencies are nor revieawable by SC.

Ruling: As a general rule, factual findings of administrative agencies, such as the CSC, that are affirmed by the CA, are conclusive upon and generally not reviewable by this Court.

However, this Court has recognized several exceptions to this rule, to wit: (1) when the findings are grounded entirely on speculation, surmises, or conjectures; (2) when the inference made is manifestly mistaken, absurd, or impossible;(3) when there is grave abuse of discretion; (4) when the judgment is based on a misapprehension of facts; (5) when the findings of facts are conflicting; (6) when in making its findings, the CA went beyond the issues of the case, or its findings are contrary to the admissions of both the appellant and the appellee; (7) when the findings are contrary to the trial court; (8) when the findings are conclusions without citation of specific evidence on which they are based; (9) when the facts set forth in the petition as well as in the petitioner's main and reply briefs are not disputed by the respondent; (10) when the findings of fact are premised on the supposed absence of evidence and contradicted by the evidence on record; and (11) when the CA manifestly overlooked certain relevant facts not disputed by the parties, which, if properly considered, would justify a different conclusion. Exceptions (4) and (11) find application here.