Facts:

In the case of Lydia I. Aguirre v. Director Cecilia R. Nieto, Civil Service Commission Regional Office V, Legaspi City, (G.R. No. 220224, August 28, 2019), the petitioner, Lydia I. Aguirre, served as the Administrative Officer II of the Department of Environment and Natural Resources - Community Environment and Natural Resources Office (DENR-CENRO). On August 1, 2005, Abundio L. Elaurza, a Tree Marker under Aguirre’s jurisdiction, lodged a complaint against her, accusing her of dishonesty. He asserted that on April 27, 2005, he was denied his full salary because Aguirre had instructed the cashier, Mrs. Edith Romero, to deduct P480.00 for his uniform, a deduction that lacked any official memorandum circular to justify it. Elaurza later sought counsel from higher officials who confirmed that the deduction ought to come from his bonus rather than his salary and advised him to appeal directly to Aguirre. When he confronted Aguirre regarding the unauthorized deduction, he claimed she

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Facts:

Background of the Case

• Lydia I. Aguirre, the petitioner, served as an Administrative Officer II at the DENR-CENRO.
• Abundio L. Elaurza, a Tree Marker at the DENR-CENRO, filed a complaint against her, alleging acts of dishonesty.
• The respondent in the case is the Civil Service Commission (CSC) Regional Office V, directed by Cecilia R. Nieto.

Factual Sequence and Allegations

• On August 1, 2005, Elaurza alleged that during his visit to the DENR-CENRO on April 27, 2005, he was informed by the cashier, Mrs. Edith Romero, that his salary could not be released in full because petitioner had ordered a deduction of P480.00 purportedly for his uniform.
• Questions were raised by Elaurza regarding the basis of such deduction because no memorandum circular authorizing such action was clearly produced or communicated.
• PENRO officials, Rodolfo Matusalim and Administrative Officer Ema Lirag, advised that deductions, if any, should be taken from bonuses and not from the regular salary and counseled Elaurza to appeal against the deduction.

Petitioner’s Conduct and Subsequent Events

• Instead of addressing the explanation or clarifying the issue with Elaurza, petitioner allegedly uttered defamatory remarks against him in a loud voice, further escalating the matter in front of other employees.
• Additional concerns emerged as, even after July 2005, Elaurza’s uniform had still not been delivered, intensifying allegations of improper conduct on the petitioner’s part.
• Elaurza’s initial complaint was dismissed on August 24, 2005 due to insufficient documentary evidence, prompting him to file a Motion for Reconsideration on October 17, 2005.

Administrative Charges and Proceedings

• On April 3, 2009, formal administrative charges were filed against petitioner for dishonesty, grave misconduct, and discourtesy in the course of official duties.
• Notices of hearing were dispatched to petitioner on April 7, 2010, and August 24, 2011. An order to submit a counter-affidavit was issued as part of the administrative process.
• Despite the scheduled hearings, petitioner contended that she did not receive any of the correspondences, with her official residence frequently closed, and her subsequent retirement compounding the communication issues.

Communication Issues and Due Process Concerns

• The CSC maintained that notices and other communications were sent via postal service, relying on the disputable presumption under Rule 131 that a mailed letter is received in the regular course of mail.
• Petitioner, however, adamantly denied receipt of these communications, citing lack of documentation such as registry return receipts for notices and orders addressed to her.
• The administrative records reflected registry return receipts for notices sent to Elaurza but none for those allegedly sent to petitioner, thus undermining the claim that she was properly informed.

CSC Decision and Aftermath

• On February 3, 2012, CSC Regional Office V rendered its decision finding petitioner guilty of serious dishonesty, discourtesy in the course of official duties, and grave misconduct.
• The penalties imposed included dismissal from service, forfeiture of retirement benefits, cancellation of eligibility for civil service examinations, and perpetual disqualification from government reemployment.
• Petitioner later discovered the CSC decision only when the GSIS suspended her pension benefits, leading her to file a petition for certiorari challenging the decision on the grounds of due process violation.

Issue:

Whether petitioner was denied due process in the administrative proceedings against her.

• Specifically, whether she was duly served with notice and afforded an opportunity to be heard prior to the imposition of severe administrative sanctions.
• Whether the reliance on the dispute-prone presumption of receipt of mailed communications was sufficient to satisfy due process requirements.

Whether the administrative decision rendered by CSC, based solely on the allegations and evidence presented by Elaurza (and absent petitioner’s input), amounts to a grave abuse of discretion.

• Whether the CSC exceeded its jurisdiction by penalizing petitioner without verifying that she indeed had actual notice of the charges and hearings.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)