CASE TITLE + FACTS and ISSUE HELD
Doctrine/Catchy-Phrase
Nakinig na nga ako, ako
pa nagkulang?
Catacutan v. People Recit-ready Digest: RULING: NO. Petitioner was
(Procedural Due Process) CATACUTAN V. PEOPLE not deprived of his right to
This case revolves due process
around a complaint of
two instructors both
working at the Surigao
del Norte School of Arts
and Trades (SNSAT) The
two were duly promoted
to a higher position by
CHED, following
standard operating
procedure such as
getting the approval of
the CSC and transferring
notices of promotion to
the related persons.
The problem arose when
the officer in charge of
SNSAT, who is petitioner
in this case, refused to
promote the two private
complainants. After
repeated requests, the
two private
complainants had no
choice but to file a
formal complaint in
court.
The main defense of the
petitioner was that the
promotion did not follow
the correct procedure.
Furthermore, he alleges
that his right to
procedural due process
was not respected as
when he was presenting
his evidence in the RTC,
namely the CA ruling
dismissing his
ADMINISTRATIVE CASE
The main issue in this
case is whether or not
Due process simply
demands an
opportunity to be heard
when the parties are
afforded a fair a
reasonable opportunity
to explain their
respective sides of the
controversy.
When one had the
opportunity to be heard
either through oral
arguments or through
pleadings, procedural
due process is satisfied.
There is no denial of
due process when the
RTC denied petitioners
introduction of the CA
ruling as it is within the
courts discretion to
reject the presentation
of evidence when it
believes that it is
irrelevant to the matter
at bar.
The CA ruling involved
a dismissal of an
ADMINISTRATIVE case,
this case is a CRIMINAL
one that is why it was
denied. The two are
independent of each
other. One continues
even the other was
dismissed.
The SC further cited
cases which talked
about the prerogative of
the trial courts to deny
evidences in the form of
Paredes v. CA and
petitioner was denied Nicolas v.
procedural due process Sandiganbayan.
because the RTC did not To summarize, due
give him the chance to process of law is not
present his evidence in denied by exclusion of
the form of the CA ruling irrelevant, immaterial or
The court held that the incompetent evidence,
trial court had the or testimony of an
prerogative to reject the incompetent witness.
evidence presented by SC affirms CA decision
the petitioner as it was PETITION DENIED
evidence irrelevant to
the matter. It was a
decision for an
administrative case
while the case pending
at bar was a criminal
one. Due process was
not denied to him as he
was given the
opportunity to be heard.
The fact that there was a
hearing and oral
arguments that were
conducted satisfies the
requirement for due
process.

FACTS: Private
complainant Georgito
Posesano was an
Instructor II with a Salary
Grade of 13, along with
Magdalena
Divinagracia, an
Education Program
Specialist II with a Salary
Grade of 16 are both
from Surigao del Norte
School of Arts and
Trades (SNSAT)

The branch of CHED in

the CAR appointed and
promoted the two
private complainants to
the position of
Vocational Instruction
Supervisor III with Salary
Grade 18. These
promotions were
approved by the CSC
and were transmitted to
petitioner and private
complainants.

However, petitioner
refused to appoint the
two to their newfound
positions. Due to this,
the private complainants
filed a complaint against
petitioner for grave
abuse of authority and
disrespect of lawful
orders before the
Ombudsman

As for the defense of the

petitioner, he reasoned
that there were some
procedural lapses with
regard to the
preparation of the
appointment papers. He
mentioned how the
papers had a letterhead
belonging to SNSAT
instead of CHED who
were the ones promoting
the two private
complainants.
Furthermore, it did not
follow the usual
procedure of mailing the
original copies of the
papers to him, instead
only duplicates were
transmitted to him. And
lastly, there was no
specified date of
effectivity.

As a result of this, the

RTC of Surigao convicted
petitioner of violating
Section 3(e) of RA 3019
citing evident bad faith,
grave abuse of authority
as well as refusal to
implement the
promotion of duly
promoted employees.
The Sandiganbayan
affirmed the decision as
well.

ISSUE: Whether or not

the petitioner was
denied his
constitutional right to
due process when the
RTC denied his
opportunity to
present the CA ruling
which denied the
administrative case
filed against him.