Paredes vs. Court of Appeals

An absolution from an administrative charge does not bar a criminal prosecution for the same acts, nor vice versa, because administrative and criminal proceedings are independent, require different quanta of proof, and may rely on different sets of evidence.

Petitioner Brigido B. Paredes served as Municipal Treasurer of Ubay, Bohol. Private respondent Bernardino Teloren, operating as Lava Marketing and Construction Supply, regularly transacted with the municipality. Seven checks totaling ₱146,578.96 were issued by the municipality to Lava Marketing. Teloren denied receiving the checks or affixing his endorsement signatures, alleging that petitioner forged the endorsements to encash the checks himself.

• The Disputed Checks: Seven checks issued by the Municipality of Ubay to Lava Marketing were presented to Teloren by the Sangguniang Bayan. Teloren disowned the signatures at the back, claiming forgery by petitioner.
• The Ombudsman Proceedings: Criminal and administrative complaints were filed against petitioner. The Ombudsman found probable cause for seven counts of Estafa through Falsification of Commercial Documents and ordered the filing of Informations. Separately, the Ombudsman found petitioner administratively guilty of grave misconduct and imposed dismissal from service.
• The Court of Appeals Administrative Ruling: Petitioner assailed the administrative finding before the Court of Appeals. The appellate court reversed the Ombudsman, finding substantial evidence wanting and crediting petitioner's explanation that he rediscounted the checks for the municipality, which explained his signature on the back.
• The Motion to Dismiss the Criminal Cases: Citing his administrative absolution, petitioner moved to dismiss the criminal cases before the RTC. The RTC denied the motion, emphasizing the independence of the proceedings and the prosecution's intention to present additional testimonial evidence.

• Futility of Criminal Proceedings: Petitioner argued that the continuation of the criminal cases is an exercise in futility. Because his administrative liability was not established by substantial evidence, his criminal liability cannot stand, as criminal cases demand a heavier quantum of proof—proof beyond reasonable doubt.

• Independence of Proceedings: Respondent countered that the investigation and adjudication of the administrative and criminal charges are entirely independent proceedings; the results in one do not conclude the other.
• Additional Evidence: Respondent manifested that the prosecution would present testimonial evidence in the criminal case that was not presented in the administrative proceeding.

• Dismissal of Criminal Case: Whether the dismissal of an administrative case against a public officer for lack of substantial evidence warrants the dismissal of a criminal case against him for the same acts.

• Dismissal of Criminal Case: The dismissal of the administrative case does not warrant the dismissal of the criminal case. Administrative and criminal proceedings are separate and distinct. They require different quanta of proof: substantial evidence for administrative cases and proof beyond reasonable doubt for criminal cases. The failure to adduce substantial evidence in the former does not ipso facto mean the heavier burden in the latter cannot be discharged, especially since the prosecution may adduce additional evidence not presented in the administrative case. Furthermore, a single act may offend two distinct provisions of law, giving rise to both criminal and administrative liability, which may be prosecuted simultaneously or successively without violating the prohibition against double jeopardy. Administrative dismissal is also not among the grounds for the total extinguishment of criminal liability under Article 89 of the Revised Penal Code.

• Independence of Administrative and Criminal Proceedings — Administrative cases are independent from criminal actions for the same act or omission. An absolution from a criminal charge is not a bar to an administrative prosecution, and vice versa. The findings and conclusions in one are not necessarily binding on the other due to the difference in the quantum of evidence required, the procedure followed, and the sanctions imposed. The dismissal of an administrative case does not foreclose criminal liability, because the two proceedings require different quanta of proof and may involve different sets of evidence.

• "One thing is administrative liability; quite another thing is the criminal liability for the same act."
• "Administrative cases require only substantial evidence, or such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. In contrast, in Criminal Case Nos. 99-525 to 99-531, respondents are required to proffer proof beyond reasonable doubt to secure petitioner’s conviction."

• Tan v. Commission on Elections, G.R. No. 112093, 237 SCRA 353 (1994) — Followed. The dismissal of an administrative case does not necessarily bar the filing of a criminal prosecution for the same or similar acts.
• Paredes, Jr. v. Sandiganbayan, 322 Phil. 709 (1996) — Followed. Administrative liability is distinct from criminal liability; an absolution in one does not preclude the other.
• Barillo v. Gervacio, G.R. No. 155088, 500 SCRA 561 (2006) — Followed. The dismissal of a criminal case on insufficiency of evidence does not foreclose administrative proceedings due to the difference in the quantum of proof. The exception in Larin v. Executive Secretary was distinguished as inapplicable.

• Article 315, Revised Penal Code — Punishes the act of swindling or estafa. Applied as the underlying crime charged in the Informations.
• Article 171, Revised Penal Code — Punishes falsification by a public officer taking advantage of official position. Applied as the mode of committing estafa charged in the Informations.
• Article 89, Revised Penal Code — Enumerates how criminal liability is totally extinguished. Cited to demonstrate that administrative dismissal is not among the grounds that extinguish criminal liability.
• Rule 133, Section 2, Revised Rules on Evidence — Defines proof beyond reasonable doubt. Cited to contrast the quantum of proof required in criminal cases with the substantial evidence required in administrative cases.

Consuelo Ynares-Santiago, Ma. Alicia Austria-Martinez