MACEDA v.

ERB

DOCTRINE: The ERB, as an administrative body is not bound by the strict or technical rules of evidence
governing court proceedings

FACTS:

Because of the outbreak of the conflict on the Persian Gulf, private respondents oil companies filed with
the ERB their applications on oil price increases. The ERB granted provisional increase (P1.42 per liter)

Petitioner Maceda filed a petition for Prohibition seeking to nullify this provisional increase he claims
that the increase in prices has to undergo the requirements of notice and hearing, however in this case
the requirements were not complied with, and therefore Maceda claims he was deprived of due
process.

In reaffirming the increase, the lower court ruled that Executive Order 172 does not preclude the board
from ordering ex-parte, a provisional increase. These provisional increases, however, will be subject to
final disposition of whether or not it should be made permanent, to reduce or increase it, or to deny the
application.

In fact, in the same order which authorized the provision increase, the ERB set the applications for
hearing with due notice to all interested parties. Petitioners Maceda failed to appear at said hearing and
at the second hearing. The notice of hearing was also published in newspapers of general circulation.

Hearing for presentation of the evidence commences and the ERB outlined the procedure to be
observed in the reception of evidence—That the oppositors and the board must have all the evidence-
in-chief to be places on record first then the examination will come later and the cross-examination will
come later.

Maceda claims that this order of relaxed procedure for presentation of proof resulted in a denial of due
process because it deprived him of finishing his cross-examination of the witnesses.

ISSUE:

W/N Maceda, through this relaxed procedure of presentation of evidence was deprived of due process

HELD:

NO. The Solicitor General has pointed out that administrative bodies may relax the procedures in the
introduction of evidence in trials. It is not improper. The ERB, as an administrative body is not bound by
the strict or technical rules of evidence governing court proceedings. In fact, Section 2, Rule I of the
Rules of Procedure Governing Hearings Before the ERB provides that—These rules shall govern
pleadings, practice and procedure before the ERB in all matters of inquiry, study, hearing, investigation
and/or any other proceeding within the jurisdiction of the Board. However, in the broader interest of
justice, the Board may, in any particular matter, except itself from these rules and apply such suitable
procedure as shall promote the objectives of the Order.