G.R. No.

167167
EUSTAQUIO B. CESA, Petitioner,
vs.
PEOPLE OF THE PHILIPPINES, Respondent.
BRION, J.:

That an administrative case is independent from the criminal action, although both arose from the same act
or omission, is elementary. Given the differences in the quantum of evidence required, the procedure
observed, the sanctions imposed, as well as in the objective of the two proceedings, the findings and
conclusions in one should not necessarily be binding on the other. Thus, as a rule, exoneration in the
administrative case is not a bar to a criminal prosecution for the same or similar acts which were the subject
of the administrative complaint or vice versa.80
If the exoneration from an administrative charge does not in itself bar criminal prosecution, then with more
reason should the principle apply where the respondent was found to have committed an administrative
infraction.

The Arias ruling squarely applies where, in the performance of his official duties, the head of an office is
being held to
answer for his act of relying on the acts of his subordinate. he Court has since applied the Arias ruling to
determine not
only criminal,91 civil92 and administrative93 liability, but even the existence of probable cause to file an
information94 in

the context of an allegation of conspiracy.

For emphasis, the petitioners are all heads of their respective offices that perform interdependent functions
in the
processing of cash advances. The petitioners’ attitude of buck-passing in the face of the irregularities in the
voucher
(and the absence of supporting documents), as established by the prosecution, and their indifference to
their individual
and collective duties to ensure that laws and regulations are observed in the disbursement of the funds of
the local
government of Cebu can only lead to a finding of conspiracy of silence and inaction