G.R. No. L-33892 July 28, 1988
FLORENCIO F. MANGUBAT, petitioner, vs. CRISPINO M. DE CASTRO, JOSE G. LUKBAN, LORENZO YGOT and TEOFILA BALTAZAR, respondents.

FACTS

The case originated from an administrative complaint for misconduct and violation of law filed against Detective Florencio Mangubat of the Cebu City Police Department on January 11, 1963. The investigation was initially conducted by the Municipal Board (later City Council) under Republic Act No. 557 . Petitioner was temporarily suspended but reinstated after sixty days. Hearings were conducted, and the case was submitted for decision. However, before a decision was rendered, the Charter of Cebu City (R.A. 3857) took effect, transferring investigative authority over city officers for neglect or misconduct to the City Fiscal. Consequently, the City Mayor forwarded the case to the Cebu City Fiscal for reinvestigation. The Assistant City Fiscal, after reviewing the records, recommended dismissal for lack of prima facie evidence. This recommendation was affirmed by the City Fiscal and sent to the Mayor in December 1965.
The Mayor requested a formal resolution with a statement of facts from the Fiscal to serve as a basis for an administrative order, but no such resolution was submitted. In 1968, the City Attorney invoked the Police Act of 1966 (R.A. 4864) and recommended the case be acted upon by the City Board of Investigators. The Mayor then forwarded the records to the Board. The Board’s Chairman, finding a formal investigation unnecessary given the Fiscal’s prior recommendation for dismissal, forwarded the complete records to the Police Commission without conducting a new investigation. The Police Commission, based on these records, rendered a decision on September 18, 1969, finding Mangubat guilty of Grave Misconduct and Violation of Law and ordering his dismissal from the service.

ISSUE

The primary issues were whether the Police Commission validly acquired jurisdiction over the administrative case and whether its proceedings violated petitioner’s constitutional right to due process.

RULING

The Supreme Court dismissed the petition and affirmed the decision of the Police Commission. On jurisdiction, the Court found the Commission properly assumed authority under the Police Act of 1966. The transmittal of the records from the City Board of Investigators to the Commission was a valid procedural step. On due process, the Court held no violation occurred. Due process in administrative proceedings is satisfied by a fair opportunity to be heard. The records showed the case was exhaustively heard before the original Municipal Board and the City Fiscal’s Office, where petitioner was afforded ample opportunity to present evidence. The Police Commission’s decision was based on these existing records, which were complete and disclosed to the parties. The Court emphasized that administrative rules of procedure should be construed liberally to achieve just, speedy, and inexpensive determinations. Requiring the Board of Investigators or the Commission to conduct a de novo hearing would elevate technicality over substantial justice, especially since the findings of the Commission were supported by substantial evidence from the record. The Court reiterated the doctrine that findings of fact by administrative agencies, when supported by substantial evidence, are accorded respect and finality.