FACTS:

Carlos R. Saunar, a former Regional Director of the National Bureau of Investigation (NBI), was involved in an official investigation regarding alleged corruption. He was later reassigned and received a subpoena to testify in a plunder case. He was relieved from duty and ordered to report to his supervisor. Saunar was later required to answer allegations and was reassigned again. He received a copy of the Office of the President decision dismissing him from service, which he appealed to the Court of Appeals (CA). The CA affirmed the decision, stating that Saunar was guilty of Gross Neglect of Duty and violating the law.

The petitioner, Saunar, argued that he was denied due process in the administrative proceedings. He claimed that the conference conducted by the PAGC was a sham and that he was not notified of the charges until after he had been formally charged. Saunar invoked the constitutional guarantee of due process and cited American jurisprudence on the topic.

Saunar argued that the administrative proceedings violated his right to due process as he was not given the opportunity to confront and cross-examine witnesses against him.

The case involves the issue of procedural due process in administrative proceedings. The petitioner argues that the termination of disability benefits without a hearing violates the guarantee of due process. The respondent argues that the eligibility for benefits is not based on financial need and that fair consideration of claims is ensured by Congress. The court discusses the concept of due process in administrative proceedings and emphasizes certain fundamental requirements.

In a labor dispute case, the Court of Industrial Relations relied on sworn statements as evidence. The employees argued that these statements should not have been admitted without the witnesses' testimony and alleged a lack of opportunity to present evidence in their defense. PAL argued that the sworn statements were admissible and that the decision was supported by substantial evidence. The Supreme Court considered relevant principles applicable to the case.

ISSUES:

1. Whether the Court of Industrial Relations must confine itself to the evidence disclosed to the parties.

2. Whether the Court of Industrial Relations can rely solely on the views of its subordinates in arriving at a decision.

3. Whether the Court of Industrial Relations must render its decision with reasons and issues clearly stated.

4. Whether the right to a hearing includes the opportunity to cross-examine witnesses.

5. Whether a formal hearing is required in administrative proceedings to satisfy the due process guarantee.

6. Whether the conduct of a formal hearing should be the general rule rather than the exception in administrative proceedings.

7. Whether or not the respondent was denied due process in the proceedings before the PAGC.

8. Whether or not the respondent should be dismissed from government service for gross neglect of duty.

9. Whether the respondent committed gross neglect of duty.

10. Whether the respondent violated Section 3(e) of R.A. No. 3019.

11. Whether or not the petitioner is entitled to full back wages from the time of his illegal dismissal until his retirement.

12. Whether or not the petitioner is entitled to receive his retirement benefits.

RULING:

1. Yes, the Court of Industrial Relations must confine itself to the evidence disclosed to the parties.

2. No, the Court of Industrial Relations cannot solely rely on the views of its subordinates in arriving at a decision.

3. Yes, the Court of Industrial Relations must render its decision with reasons and issues clearly stated.

4. No, the right to a hearing does not necessarily include the opportunity to cross-examine witnesses. It depends on the circumstances of the case.

5. A formal hearing is not required in administrative proceedings to satisfy the due process guarantee. The due process requirement is satisfied if the parties are given the opportunity to explain their respective sides through position papers or pleadings.

6. The conduct of a formal hearing should be the general rule rather than the exception in administrative proceedings. Administrative bodies have the active duty to use the authorized legal methods of securing evidence and informing itself of facts material and relevant to the controversy.

7. Yes, the respondent was denied due process in the proceedings before the PAGC. The respondent was not notified of the clarificatory hearing attended by an NBI official, thereby depriving him of the opportunity to be present and ask questions against the opposing party. The rules of the PAGC granted the respondent the right to be present during clarificatory hearings and the chance to ask questions. Due process requires a reasonable opportunity to be heard, and this opportunity should not be confined to the mere submission of position papers and affidavits.

8. The Court finds merit in reversing the respondent's dismissal from government service. While being on AWOL (absent without official leave) does not result in forfeiture of benefits or disqualification from re-employment in the government, it may constitute other administrative offenses that can lead to dismissal and forfeiture of retirement benefits. However, in this case, the respondent argues that he cannot be guilty of gross neglect of duty because he was not assigned any specific duty or responsibility by the government. The Court did not rule on this issue, as it has already determined that the respondent was denied due process.

9. The respondent did not commit gross neglect of duty. Although he was not assigned any specific task or duty and often stayed in establishments near the NBI, it was shown that he complied with lawful orders given to him, including attending court hearings. This indicates his intention to fulfill the duties and responsibilities assigned to him.

10. The respondent did not violate Section 3(e) of R.A. No. 3019. In order to be liable for this offense, it must be proven that the accused acted with manifest partiality, evident bad faith, or inexcusable negligence, and that his actions caused undue injury or gave unwarranted benefits to any party. In this case, there was no intention to abandon duty and the respondent's actions did not amount to inexcusable or gross negligence.

11. Yes, the petitioner is entitled to full back wages from the time of his illegal dismissal until his retirement. The Supreme Court held that in cases of illegal dismissal, employees in the civil service should be accorded the right to full back wages. The twin award of reinstatement and payment of full back wages are mandated by the constitutional right to security of tenure of civil service employees. The back wages should be computed from the time of his illegal dismissal up to his compulsory retirement.

12. Yes, the petitioner is entitled to receive his retirement benefits. The Supreme Court held that the petitioner should receive the retirement benefits he should have received if he were not illegally dismissed.

PRINCIPLES:

• The Court of Industrial Relations must confine itself to the evidence disclosed to the parties.

• The Court of Industrial Relations cannot solely rely on the views of its subordinates in arriving at a decision.

• The Court of Industrial Relations must render its decision with reasons and issues clearly stated.

• The right to a hearing may or may not include the opportunity to cross-examine witnesses, depending on the circumstances of the case.

• The lack of a formal hearing does not necessarily transgress the due process guarantee, but the formal hearing is a procedural right that may be invoked by a party.

• Administrative bodies are free from a strict application of technical rules of procedure and are given sufficient leeway, but the freedom does not include the setting aside of a hearing.

• Administrative bodies have the active duty to use the authorized legal methods of securing evidence and informing itself of facts material and relevant to the controversy.

• In illegal dismissal cases, a formal hearing or conference becomes mandatory when requested by the employee in writing, or substantial evidentiary disputes exist, or a company rule or practice requires it, or when similar circumstances justify it.

• The rejection of a party's right to a formal investigation may deny that party procedural due process.

• Relying solely on position papers and affidavits may have inherent limitations as the veracity of their contents cannot be readily ascertained. The examination and cross-examination of witnesses may be necessary to ferret out the truth and render a more accurate decision.

• Administrative bodies should not simply brush aside the conduct of formal hearings and claim that due process was observed by relying on position papers and/or affidavits.

• Administrative bodies should observe fairness in handling cases and not disregard their own rules of procedure.

• Due process is a malleable concept that requires fairness and equity.

• The due process requirement in administrative bodies is not as strict compared to judicial tribunals, but it still requires that parties be given a reasonable opportunity to be heard.

• The right to a hearing is a right that can be invoked by parties to thresh out substantial factual issues.

• The absence of a formal hearing does not necessarily result in the deprivation of due process, but it is only acceptable when the party does not invoke or waive the right to a hearing.

• Being on AWOL may lead to other administrative offenses and subsequent dismissal, but the specific circumstances and duties of the employee should be considered in determining guilt for gross neglect of duty.

• Gross Neglect of Duty refers to negligence characterized by the glaring want of care, willful and intentional acts or omissions in a situation where there is a duty to act, or acting with a conscious indifference to consequences.

• In order to be liable for violating Section 3(e) of R.A. No. 3019, the accused must be a public officer discharging administrative, judicial, or official functions, and must have acted with manifest partiality, evident bad faith, or inexcusable negligence, causing undue injury or giving unwarranted benefits to any party.

• Illegally dismissed government employees are entitled to full back wages and retirement benefits.

• An employee of the civil service who is illegally dismissed and later ordered reinstated is entitled to back wages and other monetary benefits from the time of illegal dismissal up to reinstatement, as it is fair and just to compensate the employee for the entire period they were wrongfully prevented from performing their duties and enjoying its benefits.

• An employee illegally dismissed is entitled to reinstatement and payment of full back wages as mandated by the constitutional right to security of tenure.

• The entitlement to full back wages means that there is no need to deduct the employee's earnings from other employment during the litigation of the case.

• In cases of illegal dismissal in the civil service, employees should be accorded the right to full back wages to uphold the constitutional right to security of tenure.

• Reinstatement may not be feasible if the employee has already retired, but the employee is still entitled to back wages and retirement benefits.