G.R. No. 114683 January 18, 2000
JESUS C. OCAMPO, petitioner, vs. OFFICE OF THE OMBUDSMAN and MAXIMO ECLIPSE, respondents.

FACTS

Petitioner Jesus C. Ocampo was the Training Coordinator of NIACONSULT, INC., a subsidiary of the National Irrigation Administration. In 1989, he coordinated a training program for foreign engineers and personally received the full training fee from the client, amounting to P204,960.00. Despite a formal demand from NIACONSULT’s president, Ocampo failed to remit the collected amount to the corporation. Consequently, an administrative complaint for serious misconduct, dishonesty, and conduct prejudicial to the service was filed against him before the Office of the Ombudsman.
During the administrative proceedings, the Ombudsman issued multiple orders directing Ocampo to file his counter-affidavit. He failed to comply despite receiving these orders and being given over a year to do so. The Ombudsman then proceeded to receive the complainant’s evidence ex-parte and subsequently found Ocampo guilty, dismissing him from service with forfeiture of benefits and perpetual disqualification. Ocampo moved for reconsideration, arguing he was denied due process as he was not afforded a chance to present his defense or access vital documents.

ISSUE

Whether the Office of the Ombudsman denied petitioner his right to due process in the administrative proceedings.

RULING

The Supreme Court ruled that there was no denial of due process. The essence of due process in administrative proceedings is simply an opportunity to be heard, which can be satisfied through the submission of pleadings. The Ombudsman amply provided this opportunity by issuing orders on February 17, 1992, and March 17, 1993, explicitly requiring Ocampo to file his counter-affidavit. His repeated and unjustified failure to comply constituted a waiver of his right to present evidence. The Court emphasized that administrative due process is not strictly equated with judicial due process; technical rules are not stringently applied. Ocampo’s claim of being denied access to documents was unsupported by evidence, as he never filed a formal motion to compel their production. His administrative liability was established by substantial evidence—the vouchers and receipts proving he received the funds and failed to account for them—which is sufficient in administrative cases. The subsequent dismissal of a related criminal case for insufficiency of evidence beyond reasonable doubt does not bar administrative action, as the quantum of proof required differs. The petition was denied, and the Ombudsman’s resolutions were affirmed.