Mateo vs Romulo, et al

GR 177875, August 8, 2016

Bersmin, J.:

Facts:

On May 28, 1990, Atty. Rodolfo D. Mateo was first employed as Attorney IV by the National
Resources Board (NWRB), He was later appointed as Executive Director of NWRB, and he took his oath
of office on January 29, 2002.

On April 4, 2003 NWRB employees filed a complaint affidavit with the Presidential Anti-Graft
Commission (PAGC), charging Rodolfo with dishonesty and usurpation authority, they alleged that he
had not disclosed the existence of a prior criminal conviction for homicide in his Personal Data Sheet
(PDS) with NWRB, and that he approved and issued numerous water permits without authority.

The PAGC required him to answer to the complaint, he complied on May 26, 2003; after formal
hearings, the PAGC ordered the parties to submit their respective memoranda on or before June 9,
2003, only the NWRB employees filed their memorandum paper.

The PAGC issued its resolution dated June 25, 2003, finding Atty. Rodolfo guilty as charged on
the falsification of his PDS. The PAGC decided that reclusion temporal should be imposed on the
petitioner, with the accessory penalty of absolute disqualification from any public office and shall remain
even if pardoned, and should be dismissed from service due to his dishonesty.

The Office of the President (OP) concurred with the findings and recommendation of the PAGC.
The OP also affirms his dismissal from service and forfeiture of retirement and other benefits; Rodolfo
sought reconsideration but the OP denied the motion.

Rodolff appealed to the Court of Appeals (CA), but on October 30, 2006 the CA denied the
petition for Review and affirmed the ruling of the OP.

Hence this appeal.

Issues:

1. Whether or not should Rodolfo be given the right to due process in administrative hearings to
confront his accusers?

2. Whether or not the penalty imposed upon Rodolfo D. Mateo was harsh penalty?

Ruling:

1. No. administrative due process simply means the opportunity to be heard, Rodolfo’s insistence on a
formal-type hearing in which he could confront his accusers has no legal basis, since he has been duly
notified by the
2. No. Current rules on administrative cases, dishonesty and grave misconduct are classified as grave
offenses punishable by dismissal; these offenses would reveal the offender’s true character, affecting his
right to hold his office and is punishable by dismissal.

Disposition:

It the court’s decision dated August 8, 2016 the petition for certiorari is denied; and affirms the
decision and Resolution of the Court of Appeals dated October 30, 2006. and April 25, 2007.