G.R. No. 219525 , August 6, 2018
Maria Theresa B. Bonot, Petitioner vs. Eunice G. Prila, Respondent

FACTS

Respondent Eunice G. Prila, an Administrative Aide at the Central Bicol State University of Agriculture (CBSUA), filed an administrative complaint for Grave Misconduct against petitioner Maria Theresa B. Bonot, a Dean at CBSUA. Prila alleged that in March 2012, Dra. Bonot uttered defamatory statements against her in the vernacular, calling her a “devil,” “shameless,” and accusing her of “fantasizing” about Dra. Bonot’s husband. Prila linked this incident to a separate claim that she had been sexually harassed by Dra. Bonot’s husband, Dr. Alden Bonot, in February 2012. Prila’s complaint was based on information relayed to her by colleagues, as she did not personally hear the statements.
The Civil Service Commission Regional Office No. V (CSCRO5) dismissed the complaint, finding the allegations baseless and hearsay, as no witness directly corroborated Prila’s charge. Dra. Bonot submitted counter-affidavits from four witnesses who denied hearing any such defamatory utterances. Prila filed a motion for reconsideration, attaching affidavits from two colleagues, Francia Alanis and Evelyn Rivero, to substantiate her claim. The Civil Service Commission (CSC) treated the motion as a petition for review but affirmed the dismissal, applying the equipoise doctrine where the evidence of both parties was evenly balanced, thus tilting in favor of the accused.

ISSUE

Whether the Court of Appeals erred in ruling that the Civil Service Commission deprived respondent Prila of her right to due process by dismissing her administrative complaint.

RULING

The Supreme Court granted the petition, reversing the Court of Appeals and reinstating the CSC’s decision. The Court held that no deprivation of due process occurred. Due process in administrative proceedings requires a fair opportunity to be heard, which was afforded to Prila. She filed her complaint, and the CSCRO5 required Dra. Bonot to answer. When Prila filed her motion for reconsideration with the new affidavits, the CSC properly treated it as a petition for review and explicitly considered this additional evidence in its April 8, 2013 Decision. The CSC’s evaluation noted the competing affidavits from both sides and applied the equipoise doctrine, a valid legal principle.
The Court emphasized that due process does not mandate a formal trial-type hearing in every administrative case; it is satisfied when parties are given a chance to submit evidence and arguments. Prila exercised this right by submitting her complaint, replying to the counter-affidavit, and filing a motion with additional evidence, all of which the CSC reviewed. The CA erred in concluding that a remand was necessary for Prila to substantiate her claims, as she had already been given and had utilized the opportunity to present her case. The Supreme Court accorded finality to the CSC’s factual findings, which were supported by substantial evidence, and found no arbitrariness in its proceedings.