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Falsification Case: Donato vs. CSC

This case involved Alejandro Donato Jr., a teacher, who was accused of falsely representing himself as Gil Arce and taking the Career Service Sub-Professional Examination in 1995 on Arce's behalf. The Civil Service Commission Region 1 (CSCRO1) conducted a trial and dismissed Donato and Arce for dishonesty and falsification of documents. Donato appealed, arguing irregularities in the proceedings. The Court upheld the dismissal, finding that the CSCRO1 and Civil Service Commission afforded the parties due process and their factual findings, affirmed by the Court of Appeals, were conclusive based on evidence presented. The Court concluded Donato failed to show sufficient reason to overturn the administrative agencies' decision.

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493 views2 pages

Falsification Case: Donato vs. CSC

This case involved Alejandro Donato Jr., a teacher, who was accused of falsely representing himself as Gil Arce and taking the Career Service Sub-Professional Examination in 1995 on Arce's behalf. The Civil Service Commission Region 1 (CSCRO1) conducted a trial and dismissed Donato and Arce for dishonesty and falsification of documents. Donato appealed, arguing irregularities in the proceedings. The Court upheld the dismissal, finding that the CSCRO1 and Civil Service Commission afforded the parties due process and their factual findings, affirmed by the Court of Appeals, were conclusive based on evidence presented. The Court concluded Donato failed to show sufficient reason to overturn the administrative agencies' decision.

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Ebbe Dy
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Title : ALEJANDRO V. DONATO, JR. vs. CIVIL SERVICE COMMISSION REG OFFICE NO.

1
Citation : G.R. No. 165788
February 7, 2007
Ponente : CALLEJO, SR., J.

Facts :
Petitioner Alejandro Donato, Jr. was a secondary school teacher at the San Pedro Apartado
National High School in Alcala, Pangasinan while Gil C. Arce was the Assessment Clerk II at the Office of
the Municipal Treasurer of the same municipality. On October 5, 1998, the Management Information
Office of the CSC in Diliman, Quezon City received an anonymous letter-complaint requesting an
investigation on the alleged dishonest act committed by Donato, Jr. It was alleged that Donato, Jr.,
falsely representing himself as Arce during the Career Service Sub-Professional Examination held in
1995,2 took the said examination in behalf of the latter.
Subsequently, a trial-type hearing was conducted where the parties, particularly Donato, Jr. and
Arce, were given the opportunity to proffer documentary and testimonial evidence. Thereafter, the
CSCRO 1, through Lorenzo S. Danipog, Director IV, rendered Decision No. 2001-1137 dated May 30, 2001
in Administrative Case No. 99-27, dismissing Donato, Jr. and Arce from the service for dishonesty and
falsification of official document.
Issue:
Whether or not there was irregularity in the proceeding undertaken by respondent.
Held:
As a general rule, factual findings of administrative agencies, such as the CSC, that are affirmed
by the CA, are conclusive upon and generally not reviewable by this Court. Indeed, in administrative
proceedings, due process is satisfied when the parties are afforded fair and reasonable opportunity to
explain their side of the controversy or given opportunity to move for a reconsideration of the action or
ruling complained of. Such minimum requirements have been satisfied in this case for, in fact, hearings
were conducted by the CSCRO 1 and the petitioner and Arce actively participated therein and even
submitted their respective evidence. Moreover, they were able to seek reconsideration of the decision
of the CSCRO 1 and, subsequently, to elevate the case for review to the CSC and the CA.
The CSCRO 1 in this case, being an administrative body with quasi-judicial powers, is not bound by
technical rules of procedure and evidence in the adjudication of cases, subject only to limitations
imposed by basic requirements of due process. As earlier opined, these basic requirements of due
process have been complied with by the CSC, including the CSCRO 1.
In fine, the CA committed no reversible error when it affirmed the resolutions of the CSC finding
the petitioner guilty of dishonesty and falsification of official document. The petitioner has miserably
failed to present any cogent reason for the Court to deviate from the salutary rule that factual findings
of administrative agencies, especially when affirmed by the CA, are generally held to be binding and final
so long as they are supported by substantial evidence in the record of the case.

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