Substantial Evidence and Administrative Due Process (Philippines)

Answer Summary

The governing quantum of proof in Philippine administrative and quasi-judicial proceedings is substantial evidence — "that amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion." NBI v. Najera, G.R. No. 237522 (June 2020); Zoleta v. Investigating Staff, G.R. No. 258888 (April 2024). Substantial evidence is more than a mere scintilla but need not be preponderant; it is a lower threshold than preponderance of evidence and far lower than proof beyond reasonable doubt. Administrative due process requires the seven cardinal primary rights first articulated in G.R. No. 46496 (27 February 1940): the right to a hearing and to present evidence; the tribunal's duty to actually consider the evidence; the need for the decision to have something to support itself; the requirement that the support be substantial evidence; the rule that the decision rest on evidence of record disclosed to the parties; the tribunal's obligation to exercise its own independent consideration of law and facts; and the duty to state the issues and reasons for the ruling. The burden of proof rests on the complainant or charging authority and never shifts; only the burden of evidence — the practical duty to produce counter-evidence once a prima facie (on its face) case exists — may shift to the respondent. A bare, uncorroborated denial carries little weight against positive, credible evidence, although a denial supported by corroborating proof may prevail if the complainant's own evidence fails to reach the substantial-evidence threshold. The 2025 Rules on Administrative Cases in the Civil Service (CSC Resolution No. 2500357) apply, under Section 2, to all disciplinary and non-disciplinary administrative cases brought before the CSC and its regional or field offices, and to national government agencies, local government units, autonomous regional governments, state and local universities and colleges, and government-owned or -controlled corporations.

The controlling provisions are Rule 133, Section 6 of the B.M. No. 411, as amended by the A.M. No. 19-08-15-SC, which renumbered the substantial-evidence rule from the former Rule 133, Section 5; Rule 131, Section 1 on burden of proof; and CSC Resolution No. 2500357 with its implementing Memorandum Circular No. 12, s. 2025. The landmark decision remains G.R. No. 46496 (27 February 1940), supplemented by G.R. No. 233596, G.R. No. 192723, G.R. No. 137473, and G.R. Nos. 172532 & 172544-45.

The essential elements are:

1. Substantial evidence — the quantum that must support every finding of administrative liability; uncorroborated or self-serving allegations do not suffice.
2. Notice and opportunity to be heard — the respondent must be informed of the charges and given a reasonable chance to answer through counter-affidavits, position papers, or similar pleadings; a trial-type hearing is not always required.
3. Specification of charges — the factual and legal bases of each offense must be clearly stated, otherwise the decision is void for due-process violation.
4. Record-based and independently deliberated decision — the decision must rest on evidence in the record disclosed to the parties and reflect the tribunal's own independent consideration, not mere adoption of a subordinate's view.
5. Reasoned decision — the decision must state the issues and the reasons for the ruling.
6. Complainant's burden — the charging authority or complainant must prove the material allegations by substantial evidence; the burden of proof never shifts.

The most common failure points are: an unverified complaint or absence of a formal charge, which voids the proceedings (G.R. No. 89687); insufficiently specified charges (G.R. No. 254336); denial of access to the evidence relied upon (G.R. No. 110798); failure to prove service of assessment notices in tax cases once receipt is denied (G.R. No. 185371; Star Sports Corporation v. Commissioner of Internal Revenue, C.T.A. Case No. 10380); and reliance on a bare denial instead of an affirmative, corroborated rebuttal.

Under the current legal regime, the 2019 Amendments renumbered the substantial-evidence rule from Rule 133, Section 5 to Rule 133, Section 6, and the 2025 RACCS update the earlier CSC Resolution No. 991936. The most recent decisions this search surfaced — Konica Minolta Marketing Services (Philippines), Inc. v. Commissioner of Internal Revenue, C.T.A. Case No. 11088 (2026) — both involve administrative due process in tax assessments; they are the latest rulings retrieved but are not the closest authority on the quantum-of-proof or CSC-specific issues.

Section I — Issue Overview

1. Quantum of proof in administrative proceedings — What quantum of proof is required in Philippine administrative proceedings, and how is substantial evidence defined and sourced from the Rules of Court - Evidence as amended by the 2019 Amendments to the Rules on Evidence, and how does it differ from preponderance of evidence and proof beyond reasonable doubt? This is the threshold question for every defense and for judicial review: a finding not supported by substantial evidence will be set aside on appeal or certiorari.

2. Administrative due process, burden of proof, and evidentiary weight of a denial — What are the requirements of administrative due process in Philippine administrative proceedings, who carries the burden of proof, what must that party establish, and what is the evidentiary weight of a denial? This is the procedural battleground: a due-process defect voids the proceeding without reaching the merits.

3. The 2025 Rules on Administrative Cases in the Civil Service — How do the 2025 Rules on Administrative Cases in the Civil Service (CSC Resolution No. 2500357) treat evidence and procedure in administrative and quasi-judicial proceedings? This is the current procedural regime for civil servants and determines the applicable pleading and evidentiary framework before the CSC.

Section II — Legal Analysis

Issue 1: What is the quantum of proof required in Philippine administrative proceedings, and how is substantial evidence defined and sourced from the Rules of Court - Evidence as amended by the 2019 Amendments to the Rules on Evidence? How does it differ from preponderance of evidence and proof beyond reasonable doubt?

Applicable law. The textual source of the substantial-evidence rule is Rule 133, Section 6 of the B.M. No. 411, as renumbered by the A.M. No. 19-08-15-SC. Before the 2019 amendments, the substantial-evidence rule was found in Rule 133, Section 5; the 2019 amendments inserted a new Section 5 on the weight to be given to expert-witness opinion and renumbered the substantial-evidence provision as Rule 133, Section 6. The full text of the amended rules is available in the Rules of Court - Evidence and the Revised Rules on Evidence at the Supreme Court E-Library. Two adjacent standards in the same rule frame the comparison: Rule 133, Section 1 governs preponderance of evidence, and Rule 133, Section 2 governs proof beyond reasonable doubt. Rule 131, Section 1, as amended, governs burden of proof and is analyzed in Issue 2.

Analysis. The three standards of proof in Philippine law form a descending scale of persuasion, and the choice among them rests on the nature of the proceeding.

1. Substantial evidence (administrative and quasi-judicial cases). Substantial evidence is "that amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion." NBI v. Najera, G.R. No. 237522 (June 2020); Zoleta v. Investigating Staff, G.R. No. 258888 (April 2024). It is "more than a mere scintilla" of evidence, but it need not be overwhelming or preponderant. Substantial evidence, Weight and Sufficiency of Evidence (Rule 133). The standard permits a conclusion without requiring the evidence to outweigh contrary proof; it asks only whether a reasonable mind, viewing the relevant evidence as a whole, could accept it as adequate to justify the conclusion reached.

2. Preponderance of evidence (civil cases). Under Rule 133, Section 1, preponderance of evidence means evidence that is of greater weight, or more convincing, as to the facts asserted. Where the scales are evenly balanced, the party with the burden of proof does not prevail. This is the intermediate standard and is higher than substantial evidence because it asks which side's proof is superior, not merely whether the proof is rationally adequate to support a finding. See Weight and Sufficiency of Evidence (Rule 133).

3. Proof beyond reasonable doubt (criminal cases). Under Rule 133, Section 2, proof beyond reasonable doubt requires a degree of proof that produces moral certainty in an unprejudiced mind that the accused is guilty; it does not mean absolute certainty, but it demands more than even a strong probability of guilt. This is the highest evidentiary bar and is reserved for the deprivation of liberty through criminal sanction. See Rules of Court - Evidence.

The reason administrative proceedings use the lowest threshold is structural: administrative adjudication is summary and expeditious in character, aimed at prompt enforcement of regulatory and disciplinary policy rather than the imposition of penal consequences. The standard has been central to administrative law since G.R. No. 46496 (27 February 1940) — whose fourth cardinal right expressly requires that the support for an administrative decision be substantial evidence — and it remains the standard in disciplinary cases before the Ombudsman, the Civil Service Commission, and other quasi-judicial bodies. A finding of administrative liability may be sustained only if supported by substantial evidence; uncorroborated or self-serving allegations will not suffice. G.R. No. 233596; G.R. No. 175201; G.R. No. 192723; G.R. No. 137473. Of these, G.R. No. 233596 is representative: it holds that administrative findings unsupported by substantial evidence cannot stand, and that self-serving assertions do not meet the standard. The recent Zoleta v. Investigating Staff (April 2024) reaffirms that same formulation in the Ombudsman context, showing the rule's continuing vigor. The practical consequence is that on judicial review, the reviewing court applies the substantial-evidence test to the administrative record; if the record lacks evidence that a reasonable mind could accept as adequate, the finding must be vacated.

Issue 2: What are the requirements of administrative due process in Philippine administrative proceedings, who carries the burden of proof, what must that party establish, and what is the evidentiary weight of a denial?

Applicable law. Administrative due process is anchored in the due process guarantee of the 1987 Constitution, as operationalized by the seven cardinal primary rights in G.R. No. 46496 (27 February 1940). The governing procedural statutes depend on the forum: Republic Act No. 6770 for Ombudsman disciplinary cases; Presidential Decree No. 807 now supplemented by the 2025 RACCS for civil-service cases (Issue 3); and the special statutory notice regime developed in tax-assessment cases. Rule 131, Section 1 of the B.M. No. 411, as amended by A.M. No. 19-08-15-SC, states that the burden of proof lies on the party who would be defeated if no evidence were given on either side, and that the burden of proof never shifts, although the burden of evidence may shift during the proceedings. See Philippine Administrative & Labor Evidence.

Analysis. The floor of administrative due process was fixed by G.R. No. 46496 in seven requirements, each of which remains controlling today:

1. The right to a hearing, including the right to present one's case and submit evidence;
2. The tribunal must actually consider the evidence presented;
3. The decision must have something to support itself;
4. That support must be substantial evidence (the standard defined in Issue 1);
5. The decision must rest on evidence adduced at the hearing, or at least contained in the record and disclosed to the parties;
6. The tribunal must act on its own independent consideration of the law and facts, not merely adopt a subordinate's view; and
7. The decision must state the issues and the reasons for the ruling.

These requirements are the minimum floor, not aspirational guides. Philippine Administrative & Labor Evidence. The jurisprudence refines them in three ways.

First, administrative due process does not always require a trial-type hearing. It is satisfied when the respondent is notified of the charges and given a reasonable opportunity to defend through counter-affidavits, position papers, and similar pleadings. G.R. No. 163859. This qualification is significant for summary disciplinary and investigative proceedings, but it does not dilute the remaining Ang Tibay requirements: the tribunal must still consider the evidence, base its decision on record evidence actually disclosed to the parties, and state its reasons.

Second, the charges themselves must be adequate. The charges must clearly specify the factual and legal bases for each offense; a decision that leaves the respondent unable to know which factual findings support which charges violates due process. G.R. No. 254336. Procedural requirements imposed by statute or civil-service rules are likewise jurisdictional in effect: an unverified complaint and the absence of a formal charge can void the proceedings. G.R. No. 89687. Where the applicable law requires the authority to first inform the employee of deficiencies and allow correction before filing charges, that preliminary step is part of due process and its omission is fatal. G.R. No. 210128. And the agency must give the respondent access to the evidence on which it relies; a Commission on Audit disallowance based on documents the respondent requested but was never shown constitutes grave abuse of discretion. G.R. No. 110798.

Third, in tax-assessment proceedings, administrative due process has a specific statutory content: the assessment must be preceded by a written notice stating the law and the facts on which the assessment is based, and the taxpayer must be given a genuine opportunity to contest it. Failure to send the required preliminary assessment notice, or failure to address the taxpayer's defenses, renders the assessment void. Case No. 11088; Commissioner of Internal Revenue v. Marina Square Properties, Inc., C.T.A. EB Case No. 3051 (C.T.A. Case No. 10349); EHS Lens Philippines, Inc. v. Commissioner of Internal Revenue, C.T.A. Case No. 9924. The two most recent rulings surfaced in this search — Konica Minolta Marketing Services (Philippines), Inc. v. Commissioner of Internal Revenue, C.T.A. Case No. 11088 (2026) — both turn on whether deficiency tax assessments are void for violation of this administrative due-process requirement. They are the latest decisions retrieved but are not the closest authority on the general quantum-of-proof or CSC-specific questions; their value is to confirm the continuing application of the notice-and-opportunity rule in tax quasi-judicial proceedings.

The burden of proof in administrative proceedings rests on the complainant or the charging authority. The complainant must prove the material allegations of the complaint by substantial evidence — the standard defined in Issue 1. G.R. Nos. 172532 & 172544-45; Zoleta v. Investigating Staff, G.R. No. 258888 (April 2024). Under Rule 131, Section 1, the burden of proof never shifts; what may shift is the burden of evidence — the practical duty to come forward with counter-evidence once a prima facie case is established. Thus, the complainant must first present substantial evidence of the acts charged; only then is the respondent expected to rebut it. In disciplinary cases such as grave misconduct, the complainant must prove the elements of the offense — including, where applicable, corruption or willful intent — by substantial evidence; mere allegation or speculation is not enough. G.R. Nos. 172532 & 172544-45. In the tax-assessment context, once a taxpayer denies receipt of the required notices, the assessing authority bears the burden of proving actual service; the presumption of regularity in official duty is overcome by the denial. G.R. No. 185371; Star Sports Corporation v. Commissioner of Internal Revenue, C.T.A. Case No. 10380. This is a situation where a denial does real work: it shifts the practical burden back to the government to prove the fact of service.

As a general matter, the evidentiary weight of a bare denial is low. A bare or general denial is self-serving negative evidence and is generally insufficient to overcome positive, credible evidence; a respondent who meets a documented charge with an unsupported denial has not discharged the burden of evidence once a prima facie case exists. Philippine Administrative & Labor Evidence. But a denial is not automatically worthless. A denial supported by corroborating evidence is weighed on its merits, and if the complainant's own evidence never reaches the substantial-evidence threshold, the denial may prevail. Id. The governing principle is that the denial matters only in relation to the quality of the affirmative evidence; it cannot by itself defeat substantial proof, but it can prevail against proof that is itself insufficient.

Issue 3: How do the 2025 Rules on Administrative Cases in the Civil Service (Civil Service Commission Resolution No. 2500357) treat evidence and procedure in administrative and quasi-judicial proceedings?

Applicable law. CSC Resolution No. 2500357 adopts the "2025 Rules on Administrative Cases in the Civil Service" (2025 RACCS). The accompanying Memorandum Circular No. 12, s. 2025 provides, at Section 2, that the rules "apply to all disciplinary and non-disciplinary administrative cases or matters brought before the CSC and/or its regional or field offices, agencies of the national government, local government units (LGUs), autonomous regional governments, state universities and colleges (SUCs) or local universities and colleges (LUCs), and government-owned or -controlled corporations (GOCCs)." The CSC has described the revision as intended to "streamline procedures and ensure administrative processes remain efficient, transparent, and accountable." CSC Revises Rules on Administrative Cases in the Civil Service. The CSC en banc's authority to regulate its own pleadings and practices is part of this procedural framework. Orientation on the 2025 Rules on Administrative Cases in the Civil Service. These 2025 rules update the earlier CSC Resolution No. 991936.

Analysis. The retrieved materials establish the adoption, scope, and objectives of the 2025 RACCS, but do not include the full text of their evidence provisions; the section addressing evidence in the retrieved summary is truncated. Accordingly, the specific evidentiary articles of the 2025 RACCS cannot be quoted section-by-section from the materials. What can be said with confidence from the retrieved sources is the following. First, the 2025 RACCS are the current CSC procedural regime: by the terms of MC No. 12, s. 2025, they govern all disciplinary and non-disciplinary administrative cases before the CSC and its regional or field offices. Second, their stated purpose is to streamline procedures while preserving efficiency, transparency, and accountability, as reported by the CSC Revises Rules on Administrative Cases in the Civil Service and reflected in the Orientation on the 2025 Rules on Administrative Cases in the Civil Service. Third, because administrative disciplinary proceedings remain quasi-judicial, the general evidentiary standard continues to be substantial evidence under Rule 133, Section 6 (Issue 1), and the due-process floor remains the Ang Tibay cardinal rights (Issue 2); the retrieved materials contain no statement in the 2025 RACCS departing from that framework. No Supreme Court decision interpreting the 2025 RACCS was found among the retrieved sources. Practitioners should obtain and review the full text of CSC Resolution No. 2500357, together with the 2025 Rules on Administrative Cases in the Civil Service guide, for the precise pleading, evidence, and motion provisions applicable to a specific CSC case.

Section III — Comparative Analysis of Divergent Rulings

Divergent outcomes on this issue. The split concerns the weight of a denial and the burden of explanation in administrative and quasi-judicial proceedings once the charging authority presents adverse evidence. In G.R. No. 175201, G.R. Nos. 172532 & 172544-45, and G.R. No. 233596, charges of bribery and grave misconduct were dismissed because the adverse evidence consisted of hearsay affidavits—affiants did not appear or lacked personal knowledge—or an equivocal check voucher; the courts ruled that these did not reach the substantial-evidence threshold, gave the respondent’s positive denial equal weight, and credited the explanation of legitimate loan transactions. Star Sports Corp. v. CIR likewise ruled that a taxpayer’s mere denial of receipt overcame the presumption of regularity and shifted the burden to the Commissioner to prove receipt. In contrast, G.R. No. 165788, G.R. No. 238077, G.R. No. 145737, G.R. No. 203536, and G.R. No. 248255 sustained dismissal or reinstated findings of dishonesty and falsification because the agency presented official or primary documentary evidence—Picture Seat Plans, Personal Data Sheets, the CSC masterlist of eligibles, or a spurious PRC card. There, the documentary discrepancies supplied substantial evidence, and the respondent’s unsubstantiated denial or explanation of tampering or mix-up failed to rebut the prima facie case. The decisive variable was therefore not the nominal standard but the probative character of the proof: a denial can neutralize hearsay or bare presumptions, but cannot by itself overturn primary, public-record evidence.

Strategic implication. To keep the respondent on the exoneration side, counsel must reduce the agency’s record to hearsay or uncorroborated items and present documentary or otherwise credible explanation, while the charging side should avoid relying on bare affidavits and instead authenticate primary records so that the denial becomes merely self-serving.

Section IV — Action Plan & Evidence Guide

Strategy Guide

The single, outcome-determinative question in Philippine administrative and quasi-judicial proceedings is whether the charging party’s evidence reaches the substantial evidence threshold required by Rule 133, Section 6, as tested against the respondent’s rebuttal and the integrity of the procedural process—since the courts consistently decide in favor of the party whose position is substantiated by primary, credible records and whose procedural rights are scrupulously observed.

1. Substantial Evidence from Primary Documents — The charging party prevails when it presents official records or authenticated documents that directly establish the material facts, as in G.R. No. 248255, G.R. No. 203536, and G.R. No. 192723, where masterlists, picture seat plans, and financial records provided the necessary evidentiary foundation.
2. Respondent’s Corroborated Rebuttal — The respondent’s denial or explanation is effective only when supported by credible, documentary proof or when the adverse evidence is hearsay or uncorroborated, as established in G.R. No. 175201, G.R. Nos. 172532 & 172544-45, and Star Sports Corp. v. CIR; a bare denial cannot overcome primary documentary evidence.
3. Burden of Proof and Reasonable-Mind Standard — The charging party always bears the burden to prove each material allegation by substantial evidence, not mere assertion, per Rule 133, Section 6; the respondent’s role is to test whether the evidence would convince a reasonable mind, as reinforced by G.R. No. 110798.
4. Procedural Due Process as a Decisive Safeguard — Any defect in notice, verification, access to evidence, or failure to observe statutory prerequisites can void the proceedings regardless of the factual merits, as seen in G.R. No. 254336, G.R. No. 89687, and G.R. No. 110798.
5. Forum-Specific Rules and Streamlining — The applicable procedural code (e.g., 2025 RACCS for CSC, Republic Act No. 6770 for Ombudsman) determines both the process and the sufficiency of the charge; misapplication or omission of these requirements can be outcome-determinative, as in G.R. No. 210128 and G.R. No. 89687.

Evidence Guide

The following types of evidence proved decisive in the retrieved cases and should be prioritized, as their presence or absence directly influenced the outcome:

• Official masterlists, eligibility records, and licensing documents — Used to establish the authenticity or falsity of credentials in G.R. No. 248255, G.R. No. 145737, and G.R. No. 203536; these primary records were outcome-determinative where discrepancies or forgeries were alleged.
• Personal Data Sheets, SALNs, and financial records — Examined to test for unexplained wealth or false declarations in G.R. No. 192723 and G.R. No. 210128; comprehensive acquisition and scrutiny of these documents was central to the findings.
• Documentary evidence supporting or rebutting transactions — Such as disbursement vouchers, receipts, board resolutions, and audit reports, as in G.R. No. 110798 and G.R. No. 254336; these established the factual basis for or against liability.
• Proof of service and receipt of notices (especially in tax cases) — The presence or absence of proof of service, such as assessment notices, was decisive in Star Sports Corp. v. CIR, determining whether due process was observed.
• Verified complaints and formal charges — The sufficiency and verification of the initiating pleadings were dispositive in G.R. No. 89687 and G.R. No. 254336; unverified or vague charges resulted in nullification of proceedings.
• Correspondence requesting access to evidence — Requests for documents and records of agency refusals, as in G.R. No. 110798, provided the factual basis for grave abuse or denial of due process arguments.
• Counter-affidavits and supporting documents — A respondent’s detailed, corroborated submissions were credited where they directly addressed the allegations and were supported by credible evidence, as in G.R. No. 210128 and G.R. No. 175201.

Gathering these specific forms of evidence and documenting both the presence and sufficiency of each at every stage is essential to either sustaining or overturning the administrative outcome.

⚠️ This is AI-generated legal research for reference only. It does not constitute legal advice. Consult a licensed Philippine attorney before making important legal decisions.

Editorial currency note (16 August 2026). The civil service disciplinary rules in force are the 2025 Rules on Administrative Cases in the Civil Service — CSC Resolution No. 2500357, promulgated 30 April 2025, published in the Daily Tribune on 19 July 2025 and, by its Section 159, effective 4 August 2025. Its Section 156 repeals the 2017 RACCS (CSC Resolution No. 1701077 dated 3 July 2017) together with all issuances inconsistent with it. The Intellegal Editorial Board verified each of these particulars against the text of the resolution as published by the Civil Service Commission. No correction was required; the report already states the 2025 rules. The sources listed below are those the research run retrieved; the 2025 text was not among them, and this note records the difference rather than concealing it.

References

Law

• The 1987 Constitution, 2 February 1987

• Implementation of Sec. 12, Art. XVIII of the 1987 Constitution (Supreme Court Administrative Circular No. 1-88), 28 January 1988

• Civil Service Decree of the Philippines or Civil Service Law of 1975 (Presidential Decree No. 807, 6 October 1975

• Revised Rules on Evidence (Rules 128-134) (B.M. No. 411, 1 July 1989

• The Ombudsman Act of 1989 (Republic Act No. 6770, 17 November 1989

• Uniform Rules on Administrative Cases in the Civil Service (CSC Resolution No. 991936, 14 September 1999

• Commentary: Philippine Administrative & Labor Evidence — intellegal.ai

• Revised Rules of Court, 1 January 1964

• Amendments to the 1989 Revised Rules on Evidence (, A.M. No. 19-08-15-SC, 8 October 2019

• 2019 Proposed Amendments to the Revised Rules on Evidence (A.M. No. 19-08-15-SC (Resolution)), 8 October 2019

• Law Summary: Rules on Evidence - Rules of Court (2019), 2019 — www.digest.ph

Jurisprudence

, G.R. Nos. 141104 & 148763-, 23 February 2021 EHS Lens Philippines, Inc. v. Commissioner of Internal Revenue, C.T.A. Case No. 9924

, G.R. Nos. 141104 & 148763-, 26 January 2024 Star Sports Corporation v. Commissioner of Internal Revenue, C.T.A. Case No. 10380 (Resolution)

, G.R. Nos. 141104 & 148763-, 21 May 2026 Commissioner of Internal Revenue v. Marina Square Properties, Inc., C.T.A. EB Case No. 3051 (C.T.A. Case No. 10349)

, G.R. Nos. 141104 & 148763-, 26 May 2026 Konica Minolta Marketing Services (Philippines), Inc. v. Commissioner of Internal Revenue, C.T.A. Case No. 10908

• Ang Tibay v. Court of Industrial Relations, G.R. No. 46496, 27 February 1940

• Buscaino v. Commission on Audit, G.R. No. 110798, 20 July 1999

• Commissioner of Internal Revenue v. Metro Star Superama, Inc., G.R. No. 185371, 8 December 2010

• De Castro v. Field Investigation Office, G.R. No. 192723, 5 June 2017

• Lupo v. Administrative Action Board, G.R. No. 89687, 26 September 1990

• Marcelo v. Bungubung, G.R. No. 175201, 23 April 2008

• Melendres v. Presidential Anti-Graft Commission, G.R. No. 163859, 15 August 2012

• Miro v. Mendoza Vda. de Erederos, G.R. Nos. 172532 & 172544-45, 20 November 2013

• Navarro v. Office of the Ombudsman, G.R. No. 210128, 17 August 2016

• Office of the Ombudsman v. Tanco, G.R. No. 233596, 14 September 2020

• Remolona v. Civil Service Commission, G.R. No. 137473, 2 August 2001

• Seares v. National Electrification Administration Board, G.R. No. 254336, 18 November 2021

Secondary Sources

• CSC Resolution No. 2500357 (2025 RACCS) — csc.gov.ph

• MC No. 12, s. 2025 — www.csc.gov.ph

• Orientation on the 2025 Rules on Administrative Cases in the Civil Service — www.sss.gov.ph