In re: Maceda

Topic: Administrative law; applicability of technical rules in administrative proceedings

DOCTRINE: Proceedings in administrative investigation are not strictly governed by the

technical rules of evidence. They are summary in nature.

It is settled that "technical rules of procedure and evidence are not strictly applied to administrative
proceedings. Thus, administrative due process cannot be fully equated with due process in its strict
judicial sense." It is enough that the party is given the chance to be heard before the case against him
is decided. Otherwise stated, in the application of the principle of due process, what is sought to be
safeguarded is not lack of previous notice but the denial of the opportunity to be heard.

SUMMARY: An anonymous complainant charges Maceda of falsifying her attendance in court so she
could attend her law classes in UEP and offers as documentary evidence the photocopies of Maceda’s
certificate of registration at UEP; her grades for the 1st, 2nd and 3rd year law subjects; and her DTRs
filed with the court. Maceda contests the admissibility of the said documents, saying that they could not
have been obtained without her consent, but does not cite the relevant court or school rules in relation
thereto. The Court rules that the said documents are admissible.