G.R. No. 177875 - Mateo vs. Romulo

The petitioner, Atty. Rodolfo D. Mateo, was first employed by the National Water Resources Board (NWRB) on May 28, 1990 as Attorney IV and later appointed as its Executive Director, taking oath of office on January 29, 2002.
During his tenure, various discrepancies and irregularities in his official documents and actions came to light.

On April 4, 2003, 38 employees of the NWRB (respondents) lodged a complaint affidavit with the Presidential Anti-Graft Commission (PAGC) against the petitioner.
The allegations included:

Failure to disclose a prior criminal conviction for homicide in his Personal Data Sheets (PDS) filed in 1997 and 2000.
Unauthorized approval and issuance of numerous water permits, including those exceeding his authority and conflicting with board resolutions.
Issuance of certificates of public convenience and necessity without proper collegial board approval.
Reassignment and transfer of personnel without adherence to established protocols regarding their rank, status, or safety.
Improper handling of personnel disciplinary actions without due process or approval by the Board.

The PAGC found that in the petitioner’s PDS, he marked “NO” to the question regarding prior criminal convictions, despite having been convicted by a final judgment of homicide in 1976 and later granted a conditional pardon.
It was noted that the conviction carried a penalty of reclusion temporal with the accessory penalty of perpetual absolute disqualification from holding public office or employment.
The petitioner, despite having been conditionally pardoned, failed to disclose the conviction in his PDS, thereby committing an act of dishonesty that prejudiced the government service.
Additionally, it was found that he exceeded his authority by approving 324 water permit applications in excess of the mandated 0.05 LPS limit as delineated in a specific Board Resolution.
The unauthorized personnel reassignments and suspensions were also deemed violations of relevant Civil Service Laws and related administrative rules.

Proceedings and Decisions by the Office of the President (OP) and the Court of Appeals (CA)

After a formal hearing and submission of position papers (with the petitioner failing to submit his memorandum), the PAGC recommended dismissal, forfeiture of retirement benefits, and perpetual disqualification from reemployment in the government service.
The OP, through its resolution dated August 20, 2003, concurred with the PAGC’s findings, emphasizing that the charge of dishonesty alone was sufficient to warrant dismissal even if committed for the first time.
The petitioner sought reconsideration by asserting reliance on an alleged absolute pardon granted by President Aquino and claiming deprivation of his right to confront his accusers.
The OP denied his motion for reconsideration, noting that he was given ample opportunity to be heard and had not properly substantiated his claim regarding the pardon.
The petitioner’s appeal to the Court of Appeals (CA) was eventually denied. The CA affirmed that administrative due process was satisfied by providing the opportunity to file an answer and position paper, even if a formal trial-type confrontation was not conducted.

Whether the petitioner was denied his constitutional right to administrative due process, particularly his right to confront his accusers during the administrative proceedings.
Whether the imposition of the harsh penalty of dismissal (with forfeiture of retirement benefits and perpetual disqualification from future government employment) was factually, legally, and evidentiary justified, considering the evidence regarding the petitioner’s criminal conviction and subsequent actions in office.