G.R. No. 140839 - Rivas vs. Sison

The Court emphasizes that due process in administrative proceedings requires the filing of charges and providing the accused with a reasonable opportunity to respond.
The precedent set in Cayago vs. Lina illustrates that due process does not necessitate a trial-type proceeding; it is satisfied when a party is notified of the charges and allowed to defend themselves.
In this case, the petitioner was informed of the charges, submitted counter-affidavits, and was represented by counsel, thus fulfilling the due process requirements.

Although the petitioner was not denied due process, the Court found the factual findings of the MTRCB and the CSC to be unsupported by evidence.
Under Rule 45 of the 1997 Rules of Civil Procedure, the Supreme Court typically does not re-examine evidence but may review factual findings if they are not substantiated or are based on a misapprehension of facts.

The Court scrutinized the sworn affidavits presented against the petitioner, finding them lacking in credibility.
The affidavits of Marcelina Concepcion and Marvin Ynigo were deemed hearsay and not credible, as they contained inconsistencies and lacked direct evidence of the petitioner’s alleged misconduct.

The Court analyzed the actions of the petitioner, specifically a phone call made to a theater owner encouraging timely payment of registration fees.
This act, even if outside the scope of his official duties, was not considered detrimental to the service, as it resulted in the theater owner fulfilling their obligations to the MTRCB.

The Court concluded that the evidence against the petitioner was insufficient to establish liability for conduct grossly prejudicial to the best interest of t...continue reading