This case has been cited 4 times or more.
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2011-09-07 |
BERSAMIN, J. |
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| The right to appeal is a mere statutory privilege, and should be exercised only in the manner prescribed by law.[36] The statutory nature of the right to appeal requires the one who avails himself of it to strictly comply with the statutes or rules that are considered indispensable interdictions against needless delays and for an orderly discharge of judicial business. In the absence of highly exceptional circumstances warranting their relaxation, like when the loftier demands of substantial justice and equity require the relaxation,[37] or when there are other special and meritorious circumstances and issues,[38] such statutes or rules should remain inviolable.[39] | |||||
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2011-02-16 |
MENDOZA, J. |
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| De Jesus cited the case of Borlongan v. Buenaventura[46] to support his argument that this administrative case should be bound by the decision in De Jesus v. Sandiganbayan.[47] In Borlongan, similar to the situation prevailing in this case, the complaint-affidavit filed with the Ombudsman also spawned two cases - a proceeding for the determination of probable cause for the filing of criminal charges, and an administrative case subject of the petition. In said case, this Court found that its factual findings regarding the proceeding for the determination of probable cause bound the disposition of the factual issues in the administrative case under the principle of conclusiveness of judgment, as both the probable cause proceeding and the administrative case require the same quantum of evidence, that is, substantial evidence. Furthermore, the factual backdrop in the proceeding for the determination of probable cause, which this Court declared as insufficient to hold respondents for trial, was the same set of facts which confronted this Court in the administrative case. | |||||
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2011-02-16 |
MENDOZA, J. |
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| Although involving different causes of action, this administrative case and the proceeding for probable cause are grounded on the same set of facts, involve the same issue of falsification of official documents, and require the same quantum of evidence[54]- substantial evidence, as was similarly found in Borlongan, and correctly relied upon by De Jesus. | |||||
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2011-02-16 |
MENDOZA, J. |
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| Meanwhile the doctrine in Montemayor v. Bundalian[57] that res judicata applies only to judicial or quasi-judicial proceedings, and not to the exercise of administrative powers, has been abandoned in subsequent cases[58] which have since applied the principle of res judicata to administrative cases. Hence, res judicata can likewise be made applicable to the case at bench. Thus, given all the foregoing, the factual finding in De Jesus that there was no false statement of facts in both sets of appointment papers, is binding in this case. | |||||