- Petitioner
- Office of the Ombudsman
- Respondent
- Tanco
- Citation
- G.R. No. 233596
- Court
- Office of the Ombudsman (OMB) to Court of Appeals (CA) to Supreme Court (SC)
- Division
- First Division
- Ponente
- J.C. Reyes, Jr., J.
- Decided
- September 14, 2020
Summary
The Office of the Ombudsman charged Vladimir L. Tanco, a Security Officer III and son of Capiz Governor Victor A. Tanco, Sr., with grave misconduct for allegedly demanding and receiving a P3,000,000.00 bribe from contractor Leodegario Labao in connection with hospital construction projects. The Ombudsman found both father and son guilty and ordered dismissal from service. However, the Court of Appeals reversed the decision, applying the condonation doctrine to the Governor and finding insufficient substantial evidence against Vladimir Tanco. The Supreme Court affirmed the CA's reversal, ruling that the evidence presented - primarily a check voucher with suspicious handwritten notations - was inadequate to prove bribery. The Court gave credence to respondent's explanation that the transaction represented legitimate loan arrangements, supported by evidence of previous similar financial dealings between the parties. The case demonstrates the requirement of substantial evidence in administrative proceedings and the distinction between private financial transactions and official misconduct.