Encinas Vs Agustin

Case: Encinas v.
Agustin
Date: April 11, 2013
Ponente: C.J. Sereno
DOCTRINE
The doctrine of res judicata applies only to judicial or quasi-judicial proceedings,
and not to the exercise of administrative powers. Administrative powers here refer to
those purely administrative in nature, as opposed to administrative proceedings that
take on a quasi-judicial character. In administrative law, a quasi-judicial proceeding
involves (a) taking and evaluating evidence; (b) determining facts based upon the
evidence presented; and (c) rendering an order or decision supported by the facts
proved. The exercise of quasi-judicial functions involves a determination, with respect
to the matter in controversy, of what the law is; what the legal rights and obligations of
the contending parties are; and based thereon and the facts obtaining, the adjudication
of the respective rights and obligations of the parties.
FACTS:
Respondents, who were then both holding positions as Fire Officer I claimed that petitioner
who was then Provincial Fire Marshall informed them that unless they gave him five thousand
pesos (P5,000) they would be relieved from their station and transferred to far-flung areas. The
respondents failed to pay the entire amount and prompted petitioner to issue instructions
effectively reassigning respondents to another station.
Respondents filed with the Bureau of Fire Protection (BFP) a letter-complaint for illegal
transfer of personnel which was later docketed by the BFP for preliminary investigation for
violation of the Anti-Graft and Corrupt Practices Act. Respondents likewise filed with the CSC
Regional Office their Joint Affidavit/Complaint for violation of the Code of Conduct and Ethical
Standards for Public Officials and Employees.
Petitioner claimed in his answer to the BFP Complaint that the investigating body
recommended that charges against him be dropped for insufficiency of evidence.
In his Answer to the formal charge of dishonesty, grave misconduct, and conduct prejudicial to
the best interest of service, petitioner alleged that they were reassigned after it was discovered
that they had conducted a fire safety inspection of establishments without any mission order.
The CSCRO issued its Decision finding petitioner administratively liable for grave misconduct
and conduct prejudicial to the best interest of service, and ordered his dismissal from service.
Petitioner filed a Motion for Reconsideration but was denied and thus filed an Appeal
Memorandum with the CSC main office.
Petitioner's appeal was subsequently denied by CSC. It ruled that substantial evidence existed
to hold petitioner administratively liable for grave misconduct and conduct prejudicial to the best
interest of the service and that no forum-shopping existed.
Petitioner filed a Petition with the CA but the CA denied petitioner's appeal. The CA found that
respondents are not guilty of forum-shopping and substantial evidence supported the CSC's
findings with regard to the administrative liability of petitioner.
ISSUE:
1. WON respondents are guilty of forum-shopping.
2. WON substantial evidence exists to hold petitioner administratively liable for grave
misconduct and conduct prejudicial to the best interest of the service?
HELD:
1. The Court ruled in negative.
In Yu v. Lim, 631 SCRA 172 (2010), the Court enumerated the requisites of forum-shopping as
follows: Forum-shopping exists when the elements of litis pendentia are present or where a final
judgment in one case will amount to res judicata in another. Litis pendentia requires the
concurrence of the following requisites: (1) identity of parties, or at least such parties as those
representing the same interests in both actions; (2) identity of rights asserted and reliefs prayed
for, the reliefs being founded on the same facts; and (3) identity with respect to the two preceding
particulars in the two cases, such that any judgment that may be rendered in the pending case,
regardless of which party is successful, would amount to res judicata in the other case.
Applying the foregoing requisites, the Court ruled that the dismissal of the BFP Complaint does
not constitute res judicata in relation to the CSCRO Complaint. Thus, there is no forum-shopping
on the part of respondents.
In order that res judicata may bar the institution of a subsequent action, the following
requisites must concur: (a) the former judgment must be final; (b) it must have been rendered by
a court having jurisdiction over the subject matter and the parties; (c) it must be a judgment on
the merits; and (d) there must be between the first and the second actions (i) identity of parties,
(ii) identity of subject matter, and (iii) identity of cause of action.
In this case, there is no "judgment on the merits" as the dismissal of the BFP Complaint was the
result of a fact-finding investigation for purposes of determining whether a formal charge for an
administrative offense should be filed. Hence, no rights and liabilities of parties were determined
therein with finality.
The CA was correct in ruling that the doctrine of res judicata applies only to judicial or
quasi-judicial proceedings, and not to the exercise of administrative powers. Administrative
powers here refer to those purely administrative in nature, as opposed to administrative
proceedings that take on a quasi-judicial character. In administrative law, a quasi-judicial
proceeding involves (a) taking and evaluating evidence; (b) determining facts based upon the
evidence presented; and (c) rendering an order or decision supported by the facts proved. The
exercise of quasi-judicial functions involves a determination, with respect to the matter in
controversy, of what the law is; what the legal rights and obligations of the contending parties are;
and based thereon and the facts obtaining, the adjudication of the respective rights and obligations
of the parties.
In this case, an analysis of the proceedings before the BFP yields the conclusion that they were
purely administrative in nature and constituted a fact-finding investigation for purposes of
determining whether a formal charge for an administrative offense should be filed against
petitioner.
2. Yes. The Court ruled that substantial evidence exists to hold the petitioner
administratively liable for grave misconduct and conduct prejudicial to the best interest of the
service under the Administrative Code of 1987.
The conclusion reached by the administrative agencies involved — after their own thorough
investigations and hearings, as well as their consideration of the evidence presented before them
and their findings thereon, especially when affirmed by the CA — must now be regarded with
great respect and finality by the Supreme Court. The alleged dismissal of respondents from the
service would not suffice to discredit them as witnesses. Scrutinizing the testimonies of
respondents, we find, as did both the CSC and the CA, that these testimonies carry more weight
than petitioner's self-serving statements and blanket denials.

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