Documentos de Académico
Documentos de Profesional
Documentos de Cultura
SUMMARY: School principal Catacutan was convicted in RTC of violation of the Anti-Graft and Corrupt Practices Act for
refusing to implement the promotion of 2 employees. On appeal, Catacutan was not allowed to present the CA decision dismissing
an administrative case against him. He claimed this was a denial of due process. The SC held that due process was not violated
because administrative cases are independent from criminal actions.
DOCTRINE: The findings in administrative cases are not binding upon the court trying a criminal case, even if the criminal
proceedings are based on the same facts and incidents which gave rise to the administrative matter. Due process of law is not denied
by the exclusion of irrelevant, immaterial, or incompetent evidence, or testimony of an incompetent witness. It is not an error to
refuse evidence which although admissible for certain purposes, is not admissible for the purpose which counsel states as the
ground for offering it.
considering the difference in the quantum of He must have acted with manifest partiality, evident
evidence, as well as the procedure followed and the bad faith or inexcusable negligence
sanctions imposed in criminal and administrative
His action caused any undue injury to any party,
proceedings, the findings and conclusions in one should
including the government or gave any private party
not necessarily be binding on the other. Notably, the
unwarranted benefits, advantage or preference in the
evidence presented in the administrative case may not
discharge of his functions.
necessarily be the same evidence to be presented in the
criminal cases
It was well within the he courts discretion to reject WHEREFORE, the petition is DENIED and the assailed
the presentation of evidence which it judiciously Decision of the Sandiganbayan promulgated on December 7,
believes irrelevant and impertinent to the proceeding on 2006 is AFFIRMED.
hand