Case Digest: YOLANDA O. ALFONSO v. OFFICE OF THE PRESIDENT and PHIL-VILLE DEVELOPMENT AND HOUSING CORPORATION

YOLANDA O. ALFONSO v. OFFICE OF THE PRESIDENT and PHIL-VILLE DEVELOPMENT AND HOUSING CORPORATION

520 SCRA 64 (2007), SECOND DIVISION

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 found that Alfonso acted maliciously, fraudulently and in bad faith hence it recommended 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.

Upon review by the Department of Justice (DOJ) of the LRA decision, it recommended to the Office of the President (OP) that Alfonso, a presidential appointee, be found guilty of Grave Misconduct and Dishonesty and be dismissed from the service. Consequently, OP issued an Administrative Order ordering the dismissal of Alfonso. Court of Appeals (CA) affirmed the Administrative Order. Alfonso came to Supreme Court to seek a reversal of the CA‘s Decision and its Resolution affirming her dismissal ordered by OP.

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:

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, petitioner 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.