GR 144464; (November, 2001) (Digest)
G.R. No. 144464 . November 27, 2001
GILDA G. CRUZ and ZENAIDA C. PAITIM, petitioners, vs. THE CIVIL SERVICE COMMISSION, respondent.
FACTS
The Civil Service Commission (CSC) received a letter-complaint alleging that during the July 30, 1989 Career Service Subprofessional examination, Zenaida C. Paitim, the Municipal Treasurer of Norzagaray, Bulacan, impersonated and took the exam for her co-employee, Gilda G. Cruz. The complaint included photographs. A preliminary verification of the official Picture Seat Plans (PSPs) from the 1989 exam and prior exams taken by Cruz revealed that the photograph attached to Cruz’s name in 1989 was not hers but resembled Paitim, and the signatures differed. Based on this prima facie finding, the CSC formally charged both petitioners with Dishonesty, Grave Misconduct, and Conduct Prejudicial to the Best Interest of the Service.
Petitioners filed an Answer with a general denial and requested a formal investigation. They subsequently moved to dismiss the case, arguing a violation of due process because the CSC acted as complainant, prosecutor, and judge. The CSC denied the motion. After a formal investigation, the hearing officer recommended dismissal. The CSC adopted this in Resolution No. 981695, finding petitioners guilty of dishonesty and ordering their dismissal from service with cancellation of Cruz’s eligibility. The Court of Appeals upheld the CSC resolution.
ISSUE
Whether the Civil Service Commission violated the petitioners’ constitutional right to due process in the administrative proceedings.
RULING
The Supreme Court ruled there was no violation of due process. The constitutional requirement of due process in administrative proceedings is satisfied when the parties are afforded a fair and reasonable opportunity to explain their side. The Court emphasized that the CSC, under its constitutional mandate and the Administrative Code, has the authority to investigate and decide administrative cases against civil service employees. This investigative and adjudicatory power can be exercised by the same body without constituting a denial of due process, provided the parties are given the opportunity to be heard.
In this case, the petitioners were formally charged in writing, informed of the accusations, and allowed to file an Answer. They explicitly elected a formal investigation and were afforded one. They participated, presented their defense, and filed motions. The Court found that the CSC’s procedure complied with the essentials of due process. The finding of guilt was based on substantial evidence, notably the conclusive discrepancy in the photographs and signatures on the official PSPs, which established that Paitim impersonated Cruz during the examination. The petition was denied, and the Court of Appeals decision was affirmed.