Is hearsay evidence admissible in administrative proceedings?

1. NACU, and DE SAGUN vs. CSC and PEZA (G.R. No. 187752, November 23,
2010)

•It is settled that, in administrative proceedings, technical rules of procedure and

evidence are not strictly applied. Administrative due process cannot be fully
equated with due process in its strict judicial sense.
•It is, therefore, not legally objectionable or violative of due process for an
administrative agency to resolve a case based solely on position papers, affidavits,
or documentary evidence submitted by the parties, as affidavits of witnesses may
take the place of their direct testimonies.

2. MIRO vs. MENDOZA, ALINGASA, MENDOZA, (G.R. Nos. 172532 & 172544-
45, November 20, 2013)
•We additionally note that the affidavits were never identified by the
complainants. All the allegations contained therein were likewise uncorroborated
by evidence, other than the NBI/Progress report.
•For the affiants' failure to identify their sworn statements, and considering the
seriousness of the charges filed, their affidavits must not be accepted at face
value and should be treated as inadmissible under the hearsay evidence rule.

3. BALASBAS vs. MONAYAO (G.R. No. 190524, February 17, 2014)

•While technicalities may be dispensed with in administrative proceedings, this
does not mean that the rules on proving allegations are entirely dispensed with.
Bare allegations are not enough; these must be supported by substantial
evidence at the very least.