G.R. No. L-49711 November 7, 1979
ZAMBALES CHROMITE MINING CO., ET AL., petitioners-appellants, vs. COURT OF APPEALS, SECRETARY OF AGRICULTURE AND NATURAL RESOURCES, DIRECTOR OF MINES, GREGORIO E. MARTINEZ, ET AL., respondents-appellees.

FACTS

The petitioners, the Zambales Chromite Mining Co. and the Nava group, filed a protest (Mines Administrative Case No. V-227) seeking to be declared the rightful locators of sixty-nine mining claims in Zambales. Director of Mines Benjamin M. Gozon dismissed their protest in 1960, finding they did not validly discover minerals or stake claims, while upholding the claims of the private respondents, the Martinez and Pabilona groups. The petitioners appealed this order to the Secretary of Agriculture and Natural Resources.
While this appeal was pending, Director Gozon was appointed as the Secretary of Agriculture and Natural Resources. Instead of recusing himself, Secretary Gozon decided the appeal (DANR Case No. 2151) in 1963, thereby reviewing and affirming his own earlier decision as Director. He again ruled against the petitioners. The petitioners then filed a complaint in the Court of First Instance of Zambales, which sustained Secretary Gozon’s decision. On appeal, the Court of Appeals initially reversed the trial court and ruled in favor of the petitioners. However, upon motion for reconsideration, the Court of Appeals issued a second decision, setting aside its first ruling. It held Secretary Gozon’s decision void for having reviewed his own work, and remanded the case to the Minister of Natural Resources for a new review.

ISSUE

Whether Secretary Benjamin M. Gozon was disqualified from deciding, in his appellate capacity as Secretary, an appeal from a decision he rendered in his original capacity as Director of Mines, thereby violating the petitioners’ right to due process.

RULING

Yes. The Supreme Court affirmed the second decision of the Court of Appeals, setting aside Secretary Gozon’s 1963 order. The core legal principle is that a reviewing official must not be the same person who rendered the decision under review, as this violates fundamental fairness and due process. Secretary Gozon, by acting as the appellate authority over his own decision as Director, effectively acted as both trial judge and appellate judge in the same case. This procedural flaw constitutes a denial of due process, as it deprives a party of a fair and impartial review. The Court rejected the trial court’s reasoning that administrative disqualification rules differ from judicial ones, emphasizing that the essence of due process applies with equal force to administrative proceedings. Consequently, the Secretary’s decision was void. The Supreme Court modified the appellate court’s remand order, directing that the petitioners’ appeal be resolved de novo by the Minister of Natural Resources, with the trial court retaining no further jurisdiction over the matter once remanded. The decision underscores that the integrity of the review process requires the absence of any suspicion of bias or prejudgment.