G.R. No. 109444 March 31, 1995
DELANO T. PADILLA, petitioner, vs. HON. PATRICIA STO. TOMAS in her capacity as Chairman of the CIVIL SERVICE COMMISSION, HON. THELMA GAMINDE in her capacity as Board Chairman II of the MERIT SYSTEM PROTECTION BOARD, and the ADMINISTRATIVE ACTION BOARD of the DEPARTMENT OF TRANSPORTATION AND COMMUNICATIONS, respondents.

FACTS

On November 2, 1988, an administrative complaint for gross dishonesty, gross neglect of duty, inefficiency and incompetence in the performance of official duties and gross violation of the law, rules and reasonable office regulations was filed against petitioner Delano T. Padilla, former officer-in-charge of the Land Transportation Office (LTO) of Bacolod City. The complaint alleged that petitioner caused and approved the registration and/or transfer of ownership of twelve (12) carnapped and stolen vehicles despite prior knowledge that existing laws, rules and regulations were violated, as he failed to require confirmation of the Certificates of Registration and Official Receipts from the issuing LTO district offices. Petitioner filed his answer denying the charges. A hearing was set for April 20, 1989, but petitioner and his counsel failed to appear despite due notice, leading to an ex-parte hearing. The Administrative Action Board (AAB) of the Department of Transportation and Communications (DOTC) found petitioner guilty and dismissed him from the service, disqualifying him from reemployment, forfeiting his leave credits and retirement benefits, and recommending the cancellation of his civil service eligibility. Petitioner filed a motion for reconsideration, which was denied. He appealed to the Merit System Protection Board (MSPB), which affirmed the AAB-DOTC decision. Petitioner then elevated the case to the Civil Service Commission (CSC), which confirmed the MSPB decision. Petitioner filed a motion for new trial, considered a second motion for reconsideration, which was denied. Petitioner then filed a Petition for Certiorari before the Supreme Court.

ISSUE

1. Whether petitioner’s constitutional right to due process was violated.
2. Whether the decisions of the DOTC, MSPB, and CSC finding petitioner guilty of the administrative charges are supported by substantial evidence.

RULING

1. No, petitioner’s constitutional right to due process was not violated. The essence of due process in administrative proceedings is the opportunity to explain one’s side or to seek reconsideration. Petitioner was furnished a copy of the charges, filed an answer, was notified of the hearing (though he and his counsel were absent), filed a motion for reconsideration where he was later allowed to present evidence, and pursued appeals to the MSPB and CSC. He was given ample opportunity to present his case through pleadings; a formal trial-type hearing is not always necessary.
2. Yes, the decisions are supported by substantial evidence. It was established that petitioner did not require the submission of Certificates of Clearance from the agencies of previous registration for the transferred motor vehicles, as mandated by DOTC Memorandum Circular No. 123. This failure facilitated the registration of carnapped and stolen vehicles using spurious documents. The findings of the administrative bodies, which have acquired expertise, are accorded respect and finality when supported by substantial evidence. The Supreme Court found no merit in the petition and dismissed it.