QUASI JUDICIAL POWER

NOTICE AND HEARING

Velasquez vs. Hernandez
G.R. No. 150732 August 31, 2004
Civil Service Commission vs. Hernandez
G.R. No. 151095 August 31, 2004
TINGA, J.
Facts: In a letter dated 25 September 1996, the Assistant Schools Division
Superintendent of the DECS-CAR, (Cordillera Administrative Region) sent a
letter to petitioner (in G.R. No. 150732) Tomas G. Velasquez, informing him of
the alleged infractions committed by respondent, Helen B. Hernandez, such as
soliciting, accepting, and receiving sums of money, in exchange for transfer or
promotion of complainant teachers. Acting on the letter, petitioner Velasquez
convened a fact-finding committee to determine the veracity of the alleged
violations of respondent and to render a formal report and recommendation. On
15
November
1996,
the
Committee
issued
an Investigation
Report recommending the filing of administrative and criminal complaints
against respondent. After due proceedings, the CSC issued Resolution No. 001375, dated 13 June 2000, finding respondent guilty of the charges against her
and ordering her dismissal from the service. Respondent appealed to the Court
of Appeals which reversed the resolutions of the CSC.
Issue: Whether or not CSC erred in rendering judgment against her in violation
of her right to due process in administrative proceedings.
Held: Administrative proceedings are governed by the "substantial evidence
rule." A finding of guilt in an administrative case would have to be sustained for
as long as it is supported by substantial evidence that the respondent has
committed the acts stated in the complaint or formal charge. As defined,
substantial evidence is such relevant evidence as a reasonable mind may accept
as adequate to support a conclusion. This is different from the quantum of
proof required in criminal proceedings, which necessitates a finding of guilt of
the accused beyond reasonable doubt. The Ombudsman, in ordering the
withdrawal of the criminal complaints against respondent was simply saying
that there is no evidence sufficient to establish her guilt beyond reasonable
doubt, which is a condition sine qua non for conviction. Ergo, the dismissal of
the criminal case will not foreclose administrative action against respondent.