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...

Facts:

Background of the Case

• In 1996, the Movie and Television Review and Classification Board (MTRCB) and the National Bureau of Investigation (NBI) conducted a joint investigation into reports that unauthorized MTRCB employees or board members were collecting annual registration fees from movie theaters for personal gain.

Incident in Iloilo

• On June 25, 1996, MTRCB and NBI agents were dispatched to Iloilo to monitor unregistered movie theaters.
• On June 26, 1996, Marcelina Concepcion, wife of a theater owner in Bacolod City, executed a sworn statement claiming that her husband paid P1,000 to petitioner Abelardo C. Rivas, believing him to be an authorized MTRCB collector. She alleged that Rivas collected fees annually at their booking office in Manila.

Tip-Off to Theater Owner

• On June 27, 1996, Leonardo Ungoco, Jr., a representative of Panay Cinema Corporation, executed an affidavit stating that Rivas called him, warning him to pay the registration fee as MTRCB agents were being sent to Iloilo. Ungoco promptly paid the fee.

Guimba Theater Incident

• On November 21, 1996, Marvin B. Inigo, owner of Guimba Theater in Nueva Ecija, executed an affidavit claiming that Rivas collected P1,200 as registration fees in 1992 and 1993 but failed to provide the corresponding certificates of registration.

Administrative Case

• Based on these sworn statements, the MTRCB filed an administrative case against Rivas for conduct grossly detrimental to the service. Rivas was accused of acting beyond his authority by collecting fees and warning theater owners of MTRCB operations.
• Rivas was temporarily transferred to the Information Unit pending investigation.

Proceedings and Motions

• The investigation was scheduled for February 13, 1997, but was reset multiple times at Rivas' request.
• Rivas filed a motion for a bill of particulars and a motion to dismiss, both of which were denied. He also filed a motion to suspend proceedings pending the NBI investigation, which was also denied.
• On March 18, 1998, Rivas filed an unverified answer, denying the allegations and claiming he only reminded theater owners to register as part of his duties.

MTRCB Decision

• On March 25, 1998, the Investigating Committee recommended Rivas' suspension for six months and permanent transfer. The MTRCB adopted this recommendation on April 28, 1998.
• Rivas appealed to the Civil Service Commission (CSC), which affirmed the suspension but set aside the transfer penalty.

Appeal to the Court of Appeals

• Rivas appealed to the Court of Appeals (CA), which dismissed his petition and affirmed the CSC's decision.
• Rivas then filed a petition for review with the Supreme Court, arguing that he was denied due process.

Issue:

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Ruling:

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Ratio:

1. Due Process: The Court held that Rivas was not denied due process. He was given multiple opportunities to present his defense, including submitting counter-affidavits, answering clarificatory questions, and filing motions. The minimum requirements of due process in administrative proceedings were satisfied.
2. Credibility of Evidence: The Court found the sworn statements of Marcelina Concepcion and Marvin Ynigo to be hearsay and lacking credibility. The statements were inconsistent and did not provide sufficient evidence to prove Rivas' liability.
3. Conduct Prejudicial to the Service: The Court ruled that Rivas' actions, even if true, did not constitute conduct grossly prejudicial to the service. His alleged warning to a theater owner resulted in the payment of fees, which benefited the MTRCB.
4. Reversal of Lower Court Decisions: The Court concluded that the evidence against Rivas was insufficient and lacked credibility, warranting the dismissal of the administrative complaint.