Case Summary (G.R. No. 42780)
Allegations Against Mateo
The complaint filed on April 4, 2003, by 38 employees of the NWRB charged Mateo with dishonesty, usurpation of authority, and conduct prejudicial to the interest of the service. Specifically, it was alleged that Mateo failed to disclose a prior criminal conviction for homicide in his personal data sheet (PDS) and approved water permits and disciplinary actions beyond his authority.
Findings of the Presidential Anti-Graft Commission (PAGC)
The PAGC conducted an investigation and issued a resolution on June 25, 2003, finding Mateo administratively liable. The investigation revealed discrepancies in his PDS, where he marked "no" to questions regarding prior convictions, despite being convicted of homicide in 1976. The PAGC highlighted that even though Mateo was granted a conditional pardon, the accessory penalty of perpetual absolute disqualification from holding public office remained in effect unless expressly remitted.
Ruling of the Office of the President (OP)
On August 20, 2003, the OP upheld the PAGC's findings, emphasizing that Mateo's dishonesty warranted dismissal from service, as it was demonstrated that he had falsely denied his criminal conviction in two separate PDSs. The OP concluded that the existing criminal disqualification prevented him from holding office, and as such, dismissal was appropriate.
Mateo's Motion for Reconsideration
Mateo filed a motion for reconsideration, arguing that he had received an absolute pardon in 1987, which should have negated the requirement to disclose his conviction. The OP denied his reconsideration, stating that he had the opportunity to present his case and did not provide evidence of the absolute pardon during previous proceedings.
Decision of the Court of Appeals (CA)
Mateo appealed to the CA, which affirmed the OP’s ruling. The CA clarified that administrative due process was fulfilled as he had the opportunity to be heard and submit evidence. The court noted that trial-type hearings were not necessary for administrative processes, and due process was satisfied through the administrative procedures that had taken place.
Key Legal Issues
Mateo raised two significant issues: (A) Whether he was denied his right to confront his accusers, and (B) Whether the dismi
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Case Overview
- The case involves Atty. Rodolfo D. Mateo (the petitioner) and various respondents, including Executive Secretary Alberto G. Romulo, concerning allegations of dishonesty, usurpation of authority, and conduct prejudicial to the service.
- The allegations stem from Mateo's failure to disclose his prior criminal conviction for homicide in his Personal Data Sheet (PDS) while serving as a public servant.
Antecedents
- Atty. Mateo was employed by the National Water Resources Board (NWRB) as Attorney IV on May 28, 1990, and later became Executive Director of the NWRB on January 29, 2002.
- On April 4, 2003, 38 employees of the NWRB lodged a complaint against him with the Presidential Anti-Graft Commission (PAGC) for various infractions, including dishonesty for not disclosing his conviction.
- Mateos filed a counter-affidavit in response to the complaint on May 26, 2003.
Findings of the PAGC
- The PAGC found Mateo administratively liable for dishonesty due to his failure to disclose his homicide conviction in his PDS dated March 12, 1997, and November 6, 2000.
- The PAGC noted that the conviction included an accessory penalty of perpetual absolute disqualification from holding public office, which was not remitted by the conditional pardon granted to him in 1979.
- The PAGC also found that Mateo had approved water permits beyo