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Administrative Law
Arellano University School of Law
aiza ebina/2015
Cuerdo vs Commission on Audit
166 SCRA 657 Extent of Judicial or Quasi-Judicial Powers of Administrative Agencies FACTS: Petitioner is the Market Supervisor I of the Market Administration Office, Office of the City Treasurer, Gingoog City. On August 1, 1986, the Market Administration Office or ticket booth, where the petitioner holds office, together with neighboring market stalls, including A and E Bakery, were destroyed by fire. Burned in the conflagration were the petitioner's cash collection and the cash tickets. The petitioner filed a written request for relief from money accountability for the loss of her cash collection and the cash tickets with the Regional Office, Commission on Audit, Cagayan de Oro City. Acting on her request, the said office conducted an investigation and its finding is "to the effect that there is positive showing of negligence on the part of the applicant in not taking necessary precaution or zeal in returning the money in the safe in order to safeguard it not only from fire but also from theft or robbery. Upon indorsement to the COA Central Office, it affirmed the stand of the COA Regional Office. he petitioner sought a reconsideration of the decision of the COA Central Office which was denied. In disclaiming liability for negligence and in seeking relief from responsibility therefor, the petitioner maintains that the money was not placed in the safe due to the disappearance of the key to the safe. Moreover, she contends that the money was due for remittance in the afternoon of that fateful day. She claims that because the fire broke out, she did not have the time to retrieve the money from the drawer of her table which was inside the Market Administration Office. She deposits that the loss was not due to a wilful negligence on her part because the immediate and direct cause of the loss was the unexpected and calamitous event of a sudden fire that consumed the public market. She argues that the alleged disappearance of the key to the safe was not looked into as no hearing was conducted in disregard of the doctrine of due process. ISSUE: Whether or not the decision of the COA finding the petitioner liable is reversible RULING: No. It is the general policy of this Court to sustain the decisions of administrative authorities not only on the basis of the doctrine of separation of powers but also for their presumed knowledgeability and even expertise in the laws they are entrusted to enforce. The legal presumption is that official duty has been duly performed; and it is particularly strong as regards administrative agencies vested with powers said to be quasi-judicial in nature, in connection with the enforcement of laws affecting particular fields of activity, the proper regulations and/or promotion of which requires a technical or special training, aside from a good knowledge and grasp of the overall conditions, relevant to said field, obtaining in the nation. The consequent policy and practice underlying our Administrative Law is that courts of justice should respect the findings of fact of said administrative agencies, unless there is absolutely no evidence in support thereof or such evidence is clearly, manifestly and patently insubstantial. Hence, courts of justice will not generally interfere with purely administrative matters which are addressed to the sound discretion of government agencies unless there is a clear showing that the latter acted arbitrarily or with grave abuse of discretion or when they have acted in a capricious and whimsical manner such that their action may amount to an excess or lack of jurisdiction. Findings of administrative agencies are generally accorded not only respect but also finality when the decision and order are not tainted with unfairness or arbitrariness that would amount to abuse of discretion or lack of jurisdiction. The findings of facts must be respected, so long as they are supported by substantial evidence even if not overwhelming or preponderant. RATIO: It is the general policy of this Court to sustain the decisions of administrative authorities not only on the basis of the doctrine of separation of powers but also for their presumed knowledgeability and even expertise in the laws they are entrusted to enforce. ---