- Petitioner
- Purisima
- Respondent
- Ricafranca
- Citation
- G.R. No. 237530
- Court
- Office of the Ombudsman to Court of Appeals (CA) to Supreme Court (SC)
- Division
- Second Division
- Ponente
- Inting, J.
- Decided
- November 29, 2021
Summary
Former PNP Chief Alan Purisima challenged his administrative liability for approving mandatory courier delivery of firearm licenses through Werfast Documentary Agency. The Ombudsman found him guilty of grave administrative offenses based on conspiracy theory, which the Court of Appeals affirmed. The Supreme Court rejected the conspiracy finding but held Purisima liable for Gross Neglect of Duty due to his willful indifference to Werfast's incompetence despite multiple warning signs. Considering his 38-year unblemished service record and numerous commendations as mitigating circumstances, the Court reduced the penalty from dismissal to one-year suspension without pay, restoring his benefits except back salaries. The case establishes important precedents on administrative accountability, the Arias doctrine's limitations, and the application of mitigating circumstances in administrative penalties.