GR 133472; (December, 2000) (Digest)
G.R. No. 133472; December 5, 2000
CONSOLACION A. LUMANCAS and YOLANDO O. URIARTE, petitioners, vs. VIRGINIA B. INTAS, respondent.
FACTS
Petitioners Consolacion A. Lumancas and Yolando O. Uriarte were regular employees of the Philippine Postal Corporation in Tandag, Surigao del Sur. They were administratively charged by their co-employee, Virginia B. Intas, for falsification, dishonesty, and grave misconduct. The complaint alleged that they made false entries in their Personal Data Sheets regarding their educational attainment, which led to their promotions. Lumancas submitted inconsistent entries across three PDS forms, variously claiming graduation from Centro Escolar University with a BS in Pharmacy and from International Harvardian University with a BS in Commerce. Uriarte was alleged to have used falsified transcripts and a Special Order from IHU to support his educational claims.
The Office of the Ombudsman found substantial evidence of falsification. For Lumancas, the Commission on Higher Education (CHED) confirmed her name was absent from IHU’s official enrollment lists, and the Bureau of Higher Education denied issuing her Special Order. For Uriarte, CHED similarly confirmed the spurious nature of his Special Order, as the Bureau of Higher Education denied its issuance. The Ombudsman denied their motion for a formal hearing, deeming it a dilatory tactic, and subsequently found them administratively liable, ordering their dismissal from service.
ISSUE
Whether the Office of the Ombudsman committed grave abuse of discretion in finding petitioners administratively liable and ordering their dismissal without conducting a formal hearing.
RULING
The Supreme Court denied the petition and affirmed the Ombudsman’s ruling. The Court held that the Ombudsman did not commit grave abuse of discretion. Administrative due process does not invariably require a trial-type hearing; it is satisfied when the parties are given a fair and reasonable opportunity to explain their side. Petitioners were afforded this opportunity through their pleadings, motions, and submissions. Their belated request for a formal hearing, filed nine months after failing to appear at a preliminary conference and to submit a required memorandum, was correctly denied as dilatory.
On the merits, the Court found substantial evidence supporting the administrative charges. The certifications from CHED and the Bureau of Higher Education constituted powerful evidence that the petitioners’ supporting academic documents were spurious and that they had not legitimately completed the degrees they claimed. Their inconsistent and false declarations in official documents constituted dishonesty and falsification, which are grave offenses warranting dismissal from service. The promotions they obtained based on these fraudulent credentials prejudiced the service and other qualified employees. The Ombudsman’s findings, being supported by substantial evidence, are conclusive upon the Court.