ADMIN - MIDTERMS CHR Art 13, Sec 17, 1987 Consti

LEGISLATIVE ENACTMENTS OMB 0 RA 9239, Optical Media Act of

1st LECTURE (usual source of creation) 2003;

BASIC CONCEPTS National Computer Center PD 1480,

Admin Agency a. is an organ of govt, other than June 11, 1978;
a court and other than a
legislature; Toll Regulatory Board PD 1112
b. which affects the rights of AUTHORITY of LAW Presidential Communications Group
private parties (delegated Executive) EO 4, July 30, 2010
c. through either adjudication or
rule-making. ORGANIZATION of ADMIN AGENCIES
Admin agency a. refer to any of the various units ACTIVITY DEFINITION EXAMPLE
(Admin code of 1987) of the Government; I. CREATION a. bringing into existence; EO 122-A (Jan 30, 1987)
b. including a dept, bureau, office, b. of an admin agency creating OMA
instrumentality or GOCC, or a 2. REORGANIZATION a. alteration of the EO 297 (July 25, 1987)
local govt or a distinct unit structure; Reorganization of OPS
therein. b. of an admin body
COVERAGE Boards, commissions, dividions, bureaus, 3. ABOLITION a. terminating the EO 13 (nov. 15, 2010)
depts., office, authority, corporation, existence; Abolishing PAGC
administration, division, or agency. b. of an admin office
4th BRANCH of the GOVT a. it is either executinve (admin), 4. DEACTIVATION a. office continues to exist; EO 191 (Jan. 7, 2000)
or legislative, or judicial; OR b. albeit dormant Deactivation of EIIB
b. it is a quasi-legislative or quasi-
judicial ABOLITION of ADMIN BODIES
BY VIRTUE OF ADMIN AGENCIES COVERED
TYPES of ADMIN BODIES P.R.O.C.I.P. CONSTI PROVISIONS a. for Constitutionally created
1. Performing business service for the Phil Postal Corp, PNR, MWSS, NEA, offices;
public NFA, NHA b. those created pursuant to law;
2. Regulating business affected w public Insurance Commission, LTFRB, ERB, c. those created pursuant to
interest NTC, HLURB delegated authority.
3. Offering grant, gratuity, special PVAO, GSIS, PAO, PhilHealth LEGISLATIVE ENACTMENTS a. those created pursuant to law;
privilege b. those created pursuant to
4. Carry function of government BOC, BIR, BID, LRA delegated authority.
5. Imbued w social policy NLRC, ECC, SSC, SEC, DAR, COA AUTHORITY of LAW a. pursuant to such delegated authority
6. Police power to regulate private SEC, MTRCB, GAB, DDB
business or individuals POWER TO REORGANIZE UNDR EO 292
OP PROPER PRESIDENT CAN: BUKLOD NG KAWANING
CREATION of ADMIN BODIES a. abolish, EIIB v ZAMORA
MANNER OF CREATION EXAMPLES Sec 31(1) consolidate, or
CONSTI PROISIONS Constitutional Commissions Art 9, 1987 EO 292 merge units; OR Facts:
(maybe self-executing) Consti b. transfer In 2000, Pres Estrada
functions from issued EO 191, ordering
Ombudsman Art 9, sec 5, 1987 Consti one unit to deactivation of EIIB and
another. transfer of its functions to

OUTSIDE OP PROPER PRESIDENT CAN:
(BUT STILL WITHIN OP) a. transfer
Sec 31 (2), (3), EO 292
b. transfer function
BOC and NBI
HELD: As far as offices in
the executive dept are
concerned, Pres power of
control may justify him to
inactivate functions of
particular office, or certain
laws of control may grant
him authority to carry out
reorganization measures.
BAGAOISAN v NTA
Facts:
In 1998, Pres Estrada
issued E) 29 Streamlining
of NTA. Drinita
Bagaoisan, et al eployed
at NTA-Batac, were
terminated from
employment.
HELD:
In the present instance,
involving neither an
abolition nor transfer of
offices, the assailed action
is a mere reorganization
under the general
provisions of the law
consisting mainly of
streamlining the NTA in
the interest of simplicity,
economy and efficiency. It
is an act well within the
authority of Pres
motivated and carried out
in good faith.
DOMINGO v ZAMORA
functions or Facts:
agencies: OP to In 1999, Pres. Estrada
other depts. Or issued EO 81 transferring
agencies; OR the Sports Programs of
DECS to PSC. Rosa
or agencies: Domingo et al went to SC,
other Dept of arguing that: a) EO 81 is
Agencies in OP unconsti for being undue
legislation by Pres.
Estrada; b) DECS is not
part of OP, Sec 31(2),(3)
of EO 292 authorizes Pres
to transfer any function or
agency of DECS to OP.
PSC is attanced to OP.
Therefore,Pres. Has
authority to transfer
function of DECS to PSC.
Reorganization of Administrative Bodies
Purposes Simplicity Larin vs. Executive Secretary
Economy
Efficiency Facts: In 1993, Pres. Ramos issues EO 132
streamlining BIR. Excise Tax Service, headed by
Larin was abolished. Then, Pres. Ramos
appointed 10 BIR Assistant Commissioners,
excluding Larin
Held: If abolition is done for political reasons or
to defeat security of tenure, or otherwise not in
good faith, no valid abolision takes place and
whatever is done is void ab initio
Limitations GOOD FAITH Dario vs. Mison
Facts: On Jan, 1988, Commissioner Salvador
Mison notified various Customs officials that
their services were terminated. Deputy
Commissioner Cesar Dario was one of the 394
officials and employees of BOC who were
separated from the service
Held: Terminating 394 BOC employees and
thereafter hiring 522 replacements is a revamp
pure and simple. Mison may carry out
reorganization under the transitory provisions of
the 1987 Constitution. But such a reorganization
should be subject to the criterion of good faith
Power to Reorganize
Executive Art. VII Sec. Buklod ng Kawaning vs. Executive Secretary TEST OF JUDICIAL FUNCTION a. not the exercise of judicial discretion
power 17, 1987 b. but the power and authority to adjud
Constituion Facts: On Jan 7, 2000, Pres. Estrada issued c. upon rights and obligations of partie
191, ordering deactivation of EIIB and transfer of
The president its functions to BOC and NBI. On March 29, INVESTIGATORY POWER
shall have the 2000, Estrada issued EO 233 providing that EIIB
control of all personnel shall be deemed separated from Principle no. 1 to investigate is not to adjudicate or adjudge.
the executive service April 30, 2000
departments, CASE: CARINO V CHR
bureaus and Held: As far as offices in the executive 204 SCRA 483
offices department are concerned, the Presidents
power of control may justify him to inactivate Facts:
functions of a particular office, or certain laws MPSTA and ACT members on Sept. 17, 1990, undertook mass concerned actions
may grant him authority to carry out to dramatize their plight for failure of authorities to act upon their grievances.
reorganization measures
Continuing Sec. 31 Book Bagaoisan vs. National Tobacco Authority Sec. Isidro Carino issued return to work order in 24 hours to striking teachers or face
authority III Chap. 10 dismissal. For failure to heed the order, teachers were charged, preventively
EO 292 Fact: On Sept 30, 1998, Pres Estrada issues EO suspended for 90 days, and temporarily replaced.
The 29 Streamlining of NTA Drianita Bagaoisan, et
president in al, all occupying different positions at NTA- Teachers complained to CHR that they were replaced without notice and for no
order to Batac, received notices of their termination reasons. Cario moved for dismissal for lack of jurisdiction. CHR denied the motion
achieve effective 30 days from receipt thereof and ruled that there had been violation of the teachers civil and political rights, which
simplicity, CHR was employed to investigate. Cario moved to elevate the case to SC.
economy and Held: In the present instance, involving neither
efficiency, an abolition nor transfer of offices, the assailed HELD:
shall have action is a mere reorganization under the a. The only thing CHR can do, if it concludes that Sec. Cario was in error, is
continuing general provisions of the law consisting mainly refer matter to appropriate government agency or tribunal for assistance,
authority to of streamlining the NTA in the interest of that would be CSC. It cannot arrogate unto itself the appellate jurisdiction of
reorganize the simplicity, economy and efficiency. It is an act CSC.
administrative well within the authority of the President b. The most that may be conceded to CHR is that it may investigate, i.e.,
structure of motivated and carried out in good faith receive evidence and make findings of the fact as regards claimed human
the OP rights violations involving civil and political rights.

POWERS OF GRANT OF INVESTIGATORY POWER

2nd LECTURE INFORMATION CHR Sec. 18, Art. 13, 1897
GATHERING Constitution To
BASIC CONCEPTS NBI investigate, on its own, or
on complaint by any party,
INVESTIGATORY POWER a. power to carry out a systematic or formal inquiry; all forms of human rights
(Inquisitorial Power) b. on violation of laws; violations involving civil
c. and to gather information on proposed and political rights.
legislations.
JUDICIAL FUNCTION a. power to adjudicate; Sec. 1, RA 157 To
b. upon rights and obligations of parties. undertake investigation of
JUDICIAL DISCRETION a. power to evaluate evidence submitted to it; crimes and other offenses
b. on the facts and circumstances presented. against the laws of the
 Philippines, upon its
initiative and as public
interest may require.
PROSECUTION Public Prosecutor Sec. 13, Art. 11, 1987
PURPOSES Constitution to
Ombudsman investigate on its own, or
on complaint by any
person, any act of
omission of any public
official, employee, office or
agency, when such act or
omission appears to be
illegal, unjust, improper or
inefficient.
AID TO OTHER POWERS SEC Sec. 5 (a), Securities
Regulation Code (RA
8799) Have jurisdiction
and supervision over all
corporations, partnerships
or associations who are
the grantees of primary
franchises and/or license
or permit issued by the
government.
Sec. 5 (d), Securities
Regulation Code (RA
8799) Regulate,
investigate or supervise
the activities of the
persons to ensure
compliance.
SCOPE AND EXTENT OF INVESTIGATORY POWERS
SCOPE EXTENT ILLUSTRATIVE CASE
1. INITIATION OF On complaint or own VILLALUZ V ZALDIVAR
INVESTIGATION motion power of control of
(examine, explore, President may extend to
inquire) power to investigate, to
suspend or to remove
officers and employees
who belong to executive
department (presidential
appointees).
2. CONDUCT OF May be held in private RUIZ V DRILON
INVESTIGATION respondent in admin
(audit, physical cases is not entitled to be
investigation, monitor) informed of the findings
and recommendations of
investigating committee.
SEC. OF JUSTICE V
LANTION due process
rights of notice and
hearing may be invoked at
evaluation stage of
extradition proceedings.
PEFIANCO V MORAL
respondent in admin case
is not entitled to be
informed of the findings
and recommendations of
investigating committee.
3. INSPECTION AND No search warrant CAMARA V MUNICIPAL
EXAMINATION required. COURT there was no
(routine inspection for emergency demanding
enforcement of Conduct inspection during immediate access. Yet no
regulations) reasonable hours. warrant was obtained.
SALAZAR V ACHACOSO
Art. 38, LC, which grants
Sec of Labor authority to
issue orders of arrest,
search and seizure, is
unconstitutional, because
secretary is not a judge.
4. ACCOUNTS, Access to documents of CATURA v CIR
RECORDS, REPORTS or person being investigated. Documents required to be
STATEMENTS produced constitutes of
most solid character as to
whether or not there was
failure to comply with
mandates of law.
5. ATTENDANCE OF No inherent power to: EVANGELISTA v
WITNESSES JARENCIO subpoena is
a. require within legal competence of
attendance; PAGRO to issue pursuant
b. put under oath; to EO 4(5) which
require to testify empowered it to summon
 witness... relevant to
investigation.
6. HEARING May be held but not OFFICE COURT
necessary part of ADMINISTRATOR v
investigation CANQUE admin due
process cannot be fully
equated with due process
in its strict judicial sense.
A formal or trial-type
hearing is required.
7. CONTEMPT Requisites: CARMELO v RAMOS
PROCEEDINGS one who invokes Sec.
(failing to appear or 1. Statutory grant; 580, RAC, must first show
refusing to produce 2. Performing he has authority to take
documents) quasi-judicial testimony or evidence
function before he can apply to
courts for punishment of
hostile witnesses.
MASANGCAY v
COMELEC When
Comelec exercises
ministerial function it
cannot exercise the power
to punish contempt
because such power is
inherently judicial in
nature.
BEDOL v COMELEC to
withhold from Comelec
the power of contempt
would render nugatory its
investigative power ,
which is an essential
incident to its mandate to
secure honest and
credible elections.
8. RULES OF Admin agency is given GAOIRAN v ALCALA in
PROCEDURE and wide latitude admin proceedings,
EVIDENCE technical rules on
procedure and evidence
are not strictly applied
I. INITIATION OF INVESTIGATION
Principle Admin agency or official may initiate
investigation on a complaint or on its own
motion.
VILLALUZ v ZALDIVAR
Facts:
Ruben Villaluz was appointed Administrator of Motor Vehicles Office (MVO).
Cong. Joaquin Roces (Chairman of the Committee on Good Government) informed
the President about the findings of his Committee concerning alleged gross
mismanagement and inefficiency committed by Villaluz in MVO. Cong. Roces
recommended the replacement of Villaluz.
President dismissed Villaluz, after the investigating committee created thereby
submitted its report.
Villaluz claims that the admin proceedings conducted against him are illegal since
there was no previous verified complaint against him.
HELD:
a. The Chief Exec, as admin head of Villaluz, is empowered to commence admin
proceedings motu propio, without need of any previous verified complaint.
2. CONDUCT OF INVESTIGATION
Principle no. 1 Respondent in admin case is not entitled
to be informed of the findings and
recommendations of investigating
committee.
RUIZ v DRILON
Facts:
Dr. Eliseo Ruiz was ordered dismissed by Pres. Corazon Aquino for dishonesty and
grave misconduct as president of Central Luzon State University (CLSU). ES Franklin
Drilon denied Ruizs MR.
Ruiz filed petition for prohibition w CA, which issued TRO. After 8 days, Ruiz filed w
SC pet for annulment of AO 218 as well as of orders of Drilon denying his MR. CA
dismissed the petition as forum shopping. Thus, Ruiz went to SC alleging that he was
not informed of the findings of the investigation conducted against him.
HELD:
a. Ruiz is not entitled to be informed of the findings and recommendations of
investigating committee created into charges filed against him.
b. He is entitled only to an admin decision that is based on substantial
evidence and a reasonable opportunity to meet the charges made against
him and the evidence presented against him during the hearings of the
investigating committees.
PEFIANCO v MORAL

Facts:
Maria Luis Moral (Chief Librarian, National Library) was charged with dishonesty,
grave misconduct and conduct prejudicial to the best interest of the service.
Moral filed Petition for Production of Investigation Committee Report purportedly to
guide her on whatever action to take. Her petition was denied. She filed for
mandamus. RTC denied motion to dismiss filed by Gloria. On appeal, CA, sustained
RTC. Gloria went to SC.
HELD:
a. A respondent in admin case is not entitled to be informed of the findings and
recommendations of any investigating committee created to inquire into
charges filed against him.
b. He is only entitled to the decision based on substantial evidence and a
reasonable opportunity to meet the charges and evidence presented against
her during the hearings of the investigating committee.
2. CONDUCT OF INVESTIGATION
Principle # 2: due process rights of notice and hearing may be invoked at evaluation
stage of extradition proceedings.
SEC. OF JUSTICE v LANTION
Facts:
Sec. Franklin Drilon formed a panel to evaluate the request for extradition by the US
government of Mark Jimenez, who is wanted in the US for various crimes.
Jimenez pending evaluation, requested for copies of extradition request and
documents submitted.
Drilon denied the requests on the ground that, inter alia, that its premature to furnish
Jimenez documents.
Judge Ralph Lantion upon pet of Jimenez directed DOJ to maintain status quo.
Drilon went to SC.
HELD:
a. one will search in vain the RP-US Extradition Treaty, the Extradition Law
(PD 1069), as well as American jurisprudence and procedures in extradition,
for any prohibition against the confinement of two basic due process rights
of notice and hearing during the evaluation stage of the extradition
proceedings.
b. Jimenez does not only face clear and present danger of loss of property or
employment, but of liberty as itself, which may eventually lead to his forcible
banishment to a foreign land.
3. INSPECTION AND EXAMINATION
Principle # 1: no search is required but inspection must be conducted during
reasonable hours.
CAMARA v MUNICIPAL COURT
Facts:
Camara was a lessee of the ground floor of an apartment building.
San Francisco Health Department received information that Camara, was using the
rear of his leasehold as residence. Claiming that the buildings occupancy permit did
not allow residential use of the ground floor, inspector of the Health Department
demanded that Camara permit an inspection of the premises.
Camara refused to allow the inspection because the inspector lacked search
warrant.
HELD:
a. There was no emergency demanding immediate access; in fact, the
inspectors made three tips to the building in an attempt to obtain Camaras
consent to the search.
b. Yet no warrant was obtained and thus Camara was unable to verify either
the need for or the appropriate limits if the inspection.
3. INSPECTION and EXAMINATION
Principle # 2: Probable cause must be determined personally by the judge.
SALAZAR v ACHACOSO
Facts:
Tomas Achacoso (POEA Administrator) ordered the seizure of documents and
paraphernalia being used as means of committing illegal recruitment owned by
Hortencia Salazar.
Salazar requested POEA that the personal properties seized be immediately
returned in the ground that said seizure violate Sec. 2, Art 3 of the Phil. Consti which
guarantees right of the people to be secure in their perons, houses, papers, and
effects against unreasonable searches and seizure of whatever nature and for any
purpose. Before POEA could act on the request, Salazar filed suit for Prohibition with
SC.
HELD:
a. The Sec. of Labor (or the POEA Administrator), not being a judge may no
longer issue search or arrest warrants.
b. Art. 38, par c of LC, empowering Labor Secretary to issue search and arrest
warrants in illegal recruitment cases is declared unconstitutional.
4. ACCOUNTS, RECORDS, REPORTS, or STATEMENTS
Principle: accounts, records, reports, or statements may be required to be delivered
and deposited with admin body at the hearing.
CATURA v CIR
Facts:
Pablo Catura and Luz Salvador President and Treasurer, respectively, of Phil.
Virginia Tobacco Admin Employees Assoc (PVTAEA), were charged before the CIR
with unauthorized disbursement of union funds.
CIR required Catura and Salvador to deliver and deposit all Assocs books of
accounts and other documents related to finances of the union.
Catura and Salvador filed MR on the grund that the order was beyond the power
CIR to issue.
HELD:
a. All that the challenged order did was to require said union officers to deliver
and deposit with CIR all docs related to its finances at the hearing.
b. The docs required to be purchased constitutes evidence of the most solid
character as to WON there was a failure to comply w the mandates of the
law.
5. ATTENDANCE OF WITNESSES
Principles: it is common for statues to confer such powers on admin agencies.
EVANGELISTA v JARENCIO
Facts:
Presidential Agency on Reforms and Govt Operations (PARGO) created through EO
4, with power to investigate immoral practices, graft and corruptions, and to
investigate any public official or employee. Further, it is vested w power to summon
witnesses, administer oaths, take testimony or evidence relevant to its investigation.
Uses. Quirico Evangelista issued subpoena to Fernando Manalastas, Public Sercice
Officer of Manila.
Manalastas instead of obeying subpoena, filed w CFI-Manila Pet for prohibition
contenting that Pargos subpoena power is exercisable when it is performing quasi-
judicial or adjudicatory function.
Judge Hilarion Jarencio granted the Pet. Thus, Usec. Evangelista went to SC.
HELD:
a. The subpoena is well within the legal competence of PARGO to issue
pursuant to EO 4(5) which empowered it to summon witness...relevant to
the investigation.
b. Subpoena power operates in all functions of PARGO. It is not merely
exercisable in quasi-judicial or adjudicatory function. To hold that subpoena
power of PARGO is confined to mere quasi-judicial or adjudicatory functions
would inactive the Agency in its investigatory functions.
6. HEARING
Principles: in admin investigation, formal or trial-type hearing is not required.
OFFICE of COURT ADM. V CANQUE
Facts:
Sylvia Canque (Clerk of Court of Cebu) was arrested by NBI after an entrance
operation. SC treated the NBI entrapment as admin complaint for grave misconduct.
Case was referred to OCA for investigation, report and recommendation. SC, upon
recommendation of OCA, reassigned case to RTC-Cebu for investigation, report and
recommendation.
Investigating Judge found Canque guilty of grave misconduct and recommended
penalty of dismissal.
OCA recommended that Report of Investigating Judge be set aside and complaint
be reinvestigated upon finding that Canque was not informed of her right to be heard
by herself and counsel during the investigation which allegedly amounted to denial of
her right to due process.
HELD:
a. The essence of due process is that a party be afforded reasonable
opportunity to be heard and to presented any evidence he may have in
support of his defense.
b. Technical rules of procedure and evidence are not strictly applied to admin
proceedings. Thus, admin due process cannot be fully equated w due
process it its strict judicial sense. A formal or trial-type hearing is not
required.
Contempt Proceedings
Principle No. 1 Power to punish contempt must be
expressly granted to administrative
body
Carmelo v. Ramos
Facts:
Jesus Carmelo tasked by virtue of an EO issued by the Mayor of Manila to head
a committee to investigate anomalies involving certain personnel, issued
subpoenas to Armando Ramos, bookkeeper, to appear in connection with an
administrative case but Ramos refused. Carmelo filed in CFI Manila a petition to
declare Ramos in contempt. CFI ruled that there is no law empowering
committees created by municipal mayors to issue subpoenas and demand
witnesses to testify under oath
Carmelo appealed to the SC invoking Sec. 580 RAC when authority to take
testimony or evidence is conferred upon, any.. committee such authority shall..
comprehend the right to administer oaths and summons witnesses Any one
who, without lawful excuse, fails to appear upon summons shall be subject to Contempt Proceedings
discipline as in case of contempt of court
Principle No. 2 When granted, the power to punish
contempt may be exercised only when
administrative body is performing
quasi-judicial functions
Held: Masangkay vs. COMELEC
One who invokes Sec. 580 must show he has authority to take testimony or Facts:
evidence before he can apply to courts for punishment of hostile witness Benjamin Masangkay (Provincial Treasurer of Aklan) was charged before the
COMELEC with contempt for having opened 3 ballot boxes containing official and
Nothing in the EO about such grant of power sample ballots not in the presence of division superintendent of schools, provincial
Only power to investigate which does not imply delegation of power to take auditor and representatives of NP, LP and Citizens Party, as required in a
testimony or evidence of witnesses whose appearance may be required by due COMELEC Resolution
process of law
Masangkay elevated the case to SC contending that even if he can be held
Contempt Proceedings guilty of contempt, the decision is null and void for lack of valid power on the part
Principle No. 2 Effectiveness of quasi-judicial power of the Commission to impose such disciplinary penalty
hinges on its authority to compel Held:
attendance of parties and compel
attendance of parties and their When COMELEC exercises ministerial functions, it cannot exercise the power to
witnesses at hearings punish contempt because such power is inherently judicial in nature
Bedol vs. COMELEC
The resolution which COMELEC tried to enforce and for whose violation the
Facts: charge for contempt was filed against Masangcay merely call for the exercise of
Comelec task force tasked to conduct factfinding investigation of allegation of an administrative or ministerial function for they merely concern the procedure to
fraud and irregularities in the conduct of the May 24, 2007 elections in be followed in the distribution of ballots and other election paraphernalia among
Maguindanao the different municipalities.

Lintang Bedol (PES for Maguindanao) refused to appear during hearing and to
answer questions before the task force. Was found guilty of contempt of the
Commission and meted 6 months imprisonment. He filed MR, which was denied.
He elevated to the SC contending that COMELEC sitting as National Board of Contempt Proceedings
Canvassers, was performing administrative not quasi-judicial functions. He argued Principle No. 2 When granted, the power to punish
that the COMELEC, in that capacity, could not punish him for contempt contempt may be exercised only when
Held: administrative body is performing
quasi-judicial functions
Comelec through task force Maguindanao was exercising its quasi judicial power Goairan vs. Alcala
in pursuit of truth behind the allegations of massive fraud during the elections in
Maguindanao Facts:
Florian Gaoiran (Head Teacher, Angadanan Agro-Industrial College) was charged
To withhold the power to punish individuals who refuse to appear during fact- by Edmon Castillejo (Administrative officer of the same school), before the CHED ,
finding investigation would render nugatory the COMELECS investigative power, for mauling him while he was performing his duties. Appended to the complaint
which is an essential incident to its constitutional mandate to secure the conduct were verified criminal complaints filed by Castillejo and sworn statements of his
of honest and credible elections witnesses for assault to person in authority. Gaoiran was preventively suspended
for 90 days. He sought reconsideration contending that a complaint was not under
oath citing EO 292 complaint against him

Angel Alcala dismissed Goairan from service, Gaoiran filed a petition with the Government agency is given wide latitude in the scope of its exercise of its
RTC, which ruled in his favor. On appeal, CA reversed RTC. investigative powers. After all, in administrative proceedings, technical rues of
Held: procedure and evidence are not strictly applied

The verified complaint that Castillejo filed against Goairan, as well as the sworn
statements of his witnesses could very well be considered as constituting the