Marcelo v. Bungubung

Summary

The Supreme Court reviewed an Ombudsman decision dismissing a Philippine Ports Authority official for grave misconduct based on bribery allegations. The complainant, who lost a security services bidding, accused the PPA manager of soliciting cash payments and a vehicle in exchange for contract awards. The Ombudsman initially found the official guilty and ordered dismissal. However, the Court of Appeals reversed, finding insufficient substantial evidence and noting the affidavits were inadmissible hearsay. Significantly, the complainant later filed an affidavit of desistance admitting he fabricated all charges. The Supreme Court affirmed the reversal, establishing that substantial evidence requires more than uncorroborated, self-serving allegations, and that an explicit admission of fabrication by the complainant undermines the probative value of the original complaint. The case reinforces due process standards in administrative proceedings and the Ombudsman's burden to establish charges with credible evidence.