This case involves Maria Luisa Moral, the former Chief Librarian of the National Library, who was charged with pilfering historical documents. An investigation committee conducted hearings and found Moral guilty, resulting in her dismissal. Moral requested a copy of the investigation report but was denied. She filed petitions which were also denied. Moral then filed a case for mandamus and injunction, which the lower courts granted. The Supreme Court ruled that Moral was not entitled to a copy of the investigation report as respondents are only entitled to the administrative decision and opportunity to address the charges, not internal committee findings. The resolution contained sufficient findings for purposes of appeal, so Moral's requests were properly denied.
This case involves Maria Luisa Moral, the former Chief Librarian of the National Library, who was charged with pilfering historical documents. An investigation committee conducted hearings and found Moral guilty, resulting in her dismissal. Moral requested a copy of the investigation report but was denied. She filed petitions which were also denied. Moral then filed a case for mandamus and injunction, which the lower courts granted. The Supreme Court ruled that Moral was not entitled to a copy of the investigation report as respondents are only entitled to the administrative decision and opportunity to address the charges, not internal committee findings. The resolution contained sufficient findings for purposes of appeal, so Moral's requests were properly denied.
This case involves Maria Luisa Moral, the former Chief Librarian of the National Library, who was charged with pilfering historical documents. An investigation committee conducted hearings and found Moral guilty, resulting in her dismissal. Moral requested a copy of the investigation report but was denied. She filed petitions which were also denied. Moral then filed a case for mandamus and injunction, which the lower courts granted. The Supreme Court ruled that Moral was not entitled to a copy of the investigation report as respondents are only entitled to the administrative decision and opportunity to address the charges, not internal committee findings. The resolution contained sufficient findings for purposes of appeal, so Moral's requests were properly denied.
This case involves Maria Luisa Moral, the former Chief Librarian of the National Library, who was charged with pilfering historical documents. An investigation committee conducted hearings and found Moral guilty, resulting in her dismissal. Moral requested a copy of the investigation report but was denied. She filed petitions which were also denied. Moral then filed a case for mandamus and injunction, which the lower courts granted. The Supreme Court ruled that Moral was not entitled to a copy of the investigation report as respondents are only entitled to the administrative decision and opportunity to address the charges, not internal committee findings. The resolution contained sufficient findings for purposes of appeal, so Moral's requests were properly denied.
Download as DOCX, PDF, TXT or read online from Scribd
Download as docx, pdf, or txt
You are on page 1/ 1
Pefianco v.
Moral (January 19, 2000)
G.R. No. 132248|Bellosillo, J.
F: Former DECS Secretary Ricardo Gloria filed a complaint against respondent Maria Luisa Moral, then Chief Librarian, Catalog Division of the National Library for dishonesty, grave misconduct and conduct prejudicial to the best interest of the service. The complaint charged Moral w/ the pilferage of some historical documents from the vaults of the Filipiniana and Asian Division of the National Library w/c were under her control and supervision, and keeping in her possession, w/o legal authority, around 41 of those missing historical documents. The DECS Investigating Committee conducted several hearings, w/ Atty. Diaz, Special Prosecutor from the DOJ representing the DECS Secretary in the administrative case. Sec. Gloria issued a resolution finding Moral guilty and ordered her dismissal. On September 30, 1996, Moral received a copy of the resolution and on oct. 1, received another resolution correcting the typographical errors found on the 1 st resolution. On Oct. 2, respondent filed a Petition for the Production of the DECS Investigation Committee Report purportedly to “guide her on whatever action would be most appropriate to take”. Her petition was denied. Unfazed, she filed a Reiteration for DECS Committee Report and DECS Resolution, w/c Sec. Gloria also denied. Moral moved for reconsideration but the motion was merely “noted” in view of the warning that the denial of the request for production of the Investigation Committee Report was final. Moral instituted an action for mandamus and injuction before the RTC. Sec. Gloria moved to dismiss the mandamus but the RTC denied his motion. He then elevated the case to the CA, who sustained the RTC. His motion for reconsideration denied by the CA, Sec. Gloria filed this petition for review. Meanwhile, Sec. Gloria was replaced by Sec. Erlinda Pefianco.
I: WON Moral should be furnished w/ a copy of the Report of the DECS Investigation Committee.
H: No. There is no law or rule w/c imposes a legal duty on petitioner to furnish respondent w/ a copy of the investigation report. On the contrary, it was held in Ruiz v. Drilon that a respondent in an administrative case is not entitled to be informed of the findings and recommendations of any investigating committee created to inquire into charges filed against him. He is entitled only to the administrative decision based on substantial evidence made of record, and a reasonable opportunity to meet the charges against her during the hearings of the investigation committee. The disputed investigation report is an internal communication between the DECS Secretary and the Investigation Committee, and it is not generally intended for the perusal of respondent or any other person, except the DECS Secretary. More importantly, the DECS resolution is complete in itself for purposes of appeal to the CSC, because it contains sufficient findings of fact and conclusion of law upon w/c respondent’s removal from office was grounded.
