In the case of CIVIL SERVICE COMMISSION vs.TRISTAN C. COLANGGO (G.R. No. 174935, April 30, 2008),  with Chief Justice Renato Corona as ponente, the Supreme Court ruled:

Administrative rules of procedure are construed liberally to promote their objective and to assist parties in obtaining just, speedy and inexpensive determination of their respective claims and defenses. Section 39 of the Uniform Rules provides:

Section 39. The direct evidence for the complainant and the respondent consist of the sworn statement and documents submitted in support of the complaint or answer as the case may be, without prejudice to the presentation of additional evidence deemed necessary but was unavailable at the time of the filing of the complaint and the answer upon which the cross-examination, by the respondent and the complainant respectively, shall be based. Following the cross-examination, there may be re-direct or re-cross examination.

Either party may avail himself of the services of counsel and may require the attendance of witnesses and the production of documentary evidence in his favor through the compulsory process of subpoena orsubpoena duces tecum.

The investigation shall be conducted for the purpose of ascertaining the truth without necessarily adhering to technical rules applicable in judicial proceedings. It shall be conducted by the disciplining authority concerned or his authorized representatives. (emphasis supplied)

The provision above clearly states that the CSC, in investigating complaints against civil servants, is not bound by technical rules of procedure and evidence applicable in judicial proceedings.

The CSC correctly appreciated the photocopies of PBET application form, picture seat plan and PDS (though not duly authenticated) in determining whether there was sufficient evidence to substantiate the charges against the respondent. Worth noting was that respondent never objected to the veracity of their contents. He merely disputed their admissibility on the ground that they were not authenticated.

As a general rule, a finding of guilt in administrative cases, if supported by substantial evidence (or “that amount of evidence which a reasonable mind might accept as adequate to justify a conclusion”), will be sustained by this Court.

 

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