FACTS:

The case of Maceda v. Energy Regulatory Board involves a petition seeking the nullification of the Energy Regulatory Board (ERB) Orders due to alleged denial of due process. The petition was filed after oil companies filed applications for oil price increases following the Persian Gulf conflict. The ERB granted a provisional increase, which was challenged by the petitioner. However, the court dismissed the petition and affirmed the ERB's authority to grant a provisional increase even without prior hearing.

Subsequently, a hearing for the oil companies' applications was set, but the petitioner failed to appear. The hearing was postponed several times due to motions for leave to file amended/supplemental applications by the oil companies. The ERB allowed the amended/supplemental applications and began the hearing for the presentation of evidence-in-chief. The petitioner argued that the ERB's decision to allow the oil companies to present evidence-in-chief before cross-examination deprived him of his right to complete cross-examination.

The court, however, disagreed with the petitioner's argument. It stated that the order of testimony in administrative bodies, such as the ERB, is within the court's discretion. The court further explained that a relaxed procedure, where the evidence-in-chief is presented first before cross-examination, is common in quasi-legislative functions like rate or price fixing.

ISSUES:

1. Whether or not there was a denial of due process when petitioner Maceda was not given the opportunity for substantial cross-examination during the hearings conducted on the second provisional increase in oil prices.

RULING:

1. The Supreme Court ruled that there was no denial of due process. The Court held that the order of testimony, both in terms of the examination of witnesses and the general course of the trial, is within the discretion of the court or administrative body. In this case, the Energy Regulatory Board (ERB) had the authority to determine the procedure to be followed. The ERB's decision to defer cross-examination and complete the presentation of evidence-in-chief first was found to be a valid exercise of its discretion. The Court emphasized that administrative bodies, such as the ERB, are not bound by the strict or technical rules of evidence governing court proceedings.

PRINCIPLES:

• Administrative bodies, such as the ERB, have the discretion to determine the order of testimony during hearings.

• Administrative bodies are not bound by the strict or technical rules of evidence governing court proceedings.