Case Digest (G.R. No. 140839)
Facts:
- Abelardo C. Rivas is the petitioner against Jesus C. Sison and Armida P. E. Siguion Reyna, former and current chairpersons of the Movie and Television Review and Classification Board (MTRCB).
- In 1996, the MTRCB, in collaboration with the National Bureau of Investigation (NBI), investigated unauthorized collection of registration fees by MTRCB employees.
- On June 25, 1996, agents monitored unregistered theaters in Iloilo.
- Rivas, an MTRCB Registration Officer II, allegedly collected fees from theater owners while posing as an authorized collector.
- Affidavits against Rivas included claims from Marcelina Concepcion, who stated her husband paid Rivas P1,000.00 for registration fees, and Leonardo Ungoco, Jr., who reported Rivas warned him to pay fees to avoid MTRCB operations.
- Marvin B. Inigo testified he paid Rivas P1,200.00 in 1992 and 1993 but did not receive a registration certificate.
- The MTRCB filed an administrative case against Rivas for conduct grossly prejudicial to the service.
- Rivas contested the charges, claiming a lack of due process, particularly the right to confront his accusers.
- The MTRCB found him guilty and suspended him for six months.
- Rivas appealed to the Civil Service Commission, which upheld the MTRCB's decision but modified the penalty regarding reassignment.
- Rivas sought relief from the Court of Appeals, which dismissed his petition, leading to the current petition for review on certiorari.
Issue:
- (Unlock)
Ruling:
- The Supreme Court granted Rivas's petition, reversing the decisions of the Court of Appeals and the MTRCB.
- The administrative complaint against Rivas was dismissed for lack of merit.
- Rivas was ordered to...(Unlock)
Ratio:
- The Supreme Court noted that while Rivas had opportunities to present his defense, the evidence against him was insufficient and lacked credibility.
- Due process in administrative proceedings requires notification of charges and a reasonable opportunity to respond.
- Rivas was able to submit counter-affidavits and present evidence, meeting the minimum due process requirements.
- The Court...continue reading
Case Digest (G.R. No. 140839)
Facts:
The case involves Abelardo C. Rivas as the petitioner against Jesus C. Sison and Armida P. E. Siguion Reyna, who are the former and present chairpersons of the Movie and Television Review and Classification Board (MTRCB), respectively. The events leading to the case began in 1996 when the MTRCB, in collaboration with the National Bureau of Investigation (NBI), initiated an investigation into reports of unauthorized MTRCB employees collecting registration fees from movie theaters. On June 25, 1996, agents were dispatched to Iloilo to monitor unregistered theaters. The investigation revealed that Rivas, an MTRCB Registration Officer II, allegedly collected fees from theater owners under the pretense of being an authorized collector.
Several affidavits were submitted against Rivas, including one from Marcelina Concepcion, who claimed her husband paid Rivas P1,000.00 for registration fees in February 1996. Another affidavit from Leonardo Ungoco, Jr. indicated that Rivas warned him to pay his registration fees to avoid MTRCB operations. Marvin B. Inigo also testified that he paid Rivas P1,200.00 in 1992 and 1993 but never received his registration certificate. Based on these statements, the MTRCB filed an administrative case against Rivas for conduct grossly prejudicial to the best interest of the service.
Rivas contested the charges, claiming he was not given due process, particularly the opportunity to confront his accusers. The MTRCB found...