Case Digest: YOLANDA O. ALFONSO v. OFFICE OF THE PRESIDENT and PHIL-VILLE DEVELOPMENT AND HOUSING CORPORATION, 520 SCRA 64 (2007)

YOLANDA O. ALFONSO v. OFFICE OF THE PRESIDENT and PHIL-VILLE DEVELOPMENT AND HOUSING CORPORATION, 520 SCRA 64 (2007)

Petitioner Yolanda O. Alfonso (Alfonso), then the register of deeds of Caloocan City, was found administratively liable for allegedly ―acquiescing to the change of the date of the registration of OCT No. 994 from May 3, 1917 to April 19, 1917, and for making it appear that there were two OCT Nos. 994. Consequently, she was dismissed from government service for grave misconduct and dishonesty. Alfonso was investigated by the Land Registration Authority (LRA) upon the request of Phil- Ville Development Corporation (Phil-Ville) who purchased some parts of the land. Phil-Ville‘s letter- complaint led to the conduct of an inquiry by the Senate Committees on Justice and Human Rights, and on Urban Planning, Housing and Resettlement which finds that Alfonso acted maliciously, fraudulently and in bad faith recommending the filing of administrative cases against her and her conspirators. On the other hand, LRA finds her guilty of Grave Misconduct and recommended her dismissal. The Office of the President subsequently dismissed Alfonso. The Court of Appeals affirmed the dismissal of Alfonso. Hence, this petition contending that her right to due process was violated. 

ISSUE:

Whether or not the Court of Appeals erred in upholding decision of the Office of the President because Alfonso‘s right to due process was violated .

HELD:

In the landmark case of Ang Tibay v. Court of Industrial Relations, this Court laid down the cardinal primary requirements of due process in administrative proceedings. Foremost of these requisites is the right to a hearing, including the right to present one‘s case and submit evidence in support thereof. The essence of due process in administrative proceedings is the opportunity to explain one‘s side or to seek a reconsideration of the action or ruling complained of.
As aptly observed by the CA, Alfonso was given every opportunity to explain her side and to present evidence in her defense during the administrative investigation conducted by the LRA. Records sufficiently show that in compliance with the ―show-cause letter of the LRA Administrator, she submitted her written explanation, and that during the pre-trial conferences, she presented documentary evidence.
Likewise, the quantum of proof required in an administrative proceeding is only substantial evidence or that amount of relevant evidence that a reasonable mind might accept as adequate to support a conclusion. The standard of substantial evidence is satisfied when there is reasonable ground to believe that the person indicted was responsible for the alleged wrongdoing or misconduct. In the case at bar, Alfonso stood charged not for changing the date of registration of OCT No. 994 but rather, she was indicted for acquiescing to the change by (1) issuing conflicting ―certifications‖ on the date of issuance of OCT No. 994; and (2) for making it appear that there were two OCT Nos. 994. Thus, her protestations that she had no hand in the alteration are unavailing.
―Serious misconduct, as a valid cause for the dismissal of an employee, is improper or wrong conduct; the transgression of some established and definite rule of action; a forbidden act or dereliction of duty, which is willful and intentional neglect and not mere error in judgment. It must be grave and aggravated in character and not merely trivial or unimportant.. In addition, it must be directly related and/or connected to the performance of official duties. Without question, all of these requisites are present in this case. Alfonso is thus administratively liable for serious misconduct.