Miro v. Vda. de Erederos

Summary

LTO Regional Office VII officials were charged with grave misconduct for allegedly selling confirmation certificates at P2,500 per pad instead of issuing them free. The Deputy Ombudsman found them guilty based on complainants' affidavits and an NBI report. However, the Court of Appeals reversed this decision, finding the evidence to be hearsay lacking personal knowledge. The Supreme Court affirmed the CA, emphasizing that substantial evidence is required in administrative cases and that hearsay evidence cannot satisfy this standard. The case establishes important precedents on evidentiary standards in administrative proceedings, the hearsay rule's application to affidavits, and the limits of relaxed procedural rules in quasi-judicial bodies. The Court distinguished between non-hearsay (fact that statements were made) and legal hearsay (truth of facts asserted), ultimately dismissing all charges for lack of substantial evidence.