POLITICAL LAW AND PUBLIC INTERNATIONAL LAW > XIII. ADMINISTRATIVE LAW > C. Powers of Administrative Agencies > 2. Quasi-Judicial or Adjudicatory Power > a. Administrative Due Process

Introduction to Administrative Due Process

Administrative due process refers to the procedural standards and protections afforded to individuals or entities in proceedings before administrative agencies exercising quasi-judicial or adjudicatory functions. These agencies are tasked with resolving disputes, interpreting laws, and issuing decisions affecting rights and obligations. Although these agencies do not operate like traditional courts, they are still required to observe fundamental principles of fairness and justice as enshrined in the Constitution.

In the Philippines, due process in administrative proceedings finds its basis in Article III, Section 1 of the 1987 Constitution, which states:

"No person shall be deprived of life, liberty, or property without due process of law, nor shall any person be denied the equal protection of the laws."

Administrative due process ensures that individuals or entities involved in such proceedings are provided with an opportunity to be heard and defend themselves before an impartial tribunal.

1. Nature of Quasi-Judicial or Adjudicatory Power of Administrative Agencies

Quasi-judicial power is the authority granted to administrative agencies to resolve disputes, make findings of fact, apply legal standards, and issue binding decisions or orders. When exercising these powers, agencies effectively perform functions similar to judicial bodies, hence the term "quasi-judicial."

Key Elements of Quasi-Judicial Power

Adjudication: Agencies determine rights, obligations, and liabilities through a formal or informal hearing process.
Issuance of Orders: Agencies can issue enforceable orders, decisions, or rulings that affect the parties involved.
Findings of Fact: Administrative agencies are tasked with determining the facts of the case based on evidence presented during the proceedings.
Application of Law: Agencies apply relevant laws, rules, and regulations to the facts of the case to arrive at a decision.

2. Requirements of Administrative Due Process

In the exercise of their quasi-judicial powers, administrative agencies must adhere to the requirements of administrative due process. The concept is rooted in both substantive and procedural due process principles:

Substantive Due Process:

Substantive due process ensures that the actions and decisions of administrative agencies are fair, reasonable, and not arbitrary. An agency's decision must be grounded on a legitimate government interest, supported by facts, and must not violate constitutional rights.

Procedural Due Process:

Procedural due process requires compliance with the following essential requisites:

Right to Notice:
- The party involved must be informed of the nature and cause of the accusation or action being taken against them.
- Notice must be clear and specific, indicating the time, place, and nature of the hearing or proceeding.
- Proper service of notice is required to ensure that the party is given a reasonable opportunity to prepare a defense or respond.
Opportunity to be Heard:
- The right to be heard is fundamental in administrative proceedings. The affected party must be given a fair chance to present their case, submit evidence, and argue their position.
- In administrative hearings, the right to be heard does not necessarily require a full-blown trial-type proceeding. What is required is a reasonable opportunity to present one’s case.
- Representation by counsel is generally allowed, but in some informal administrative proceedings, parties may represent themselves.
Impartial Tribunal:
- The decision-maker must be impartial and free from bias or conflict of interest. The tribunal must evaluate the evidence and arguments presented based on merits and law.
- A biased or prejudiced decision-maker violates the requirement of fairness under due process.
- Administrative officers or tribunals must adhere to the principle of "cold neutrality of an impartial judge."
Consideration of Evidence:
- The administrative agency must base its decision on substantial evidence presented during the proceedings. "Substantial evidence" refers to such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.
- Decisions must not be based on mere conjecture or arbitrary considerations.
Decision Rendered on the Merits:
- The decision of the administrative agency must be based on the merits of the case, as established by the facts and the law.
- The decision must clearly state the findings of fact, applicable law, and the reasons for the conclusion reached by the agency.
- The decision must also be final, subject to any administrative appeals or judicial review, as provided by law.

3. The Due Process Standard in Administrative Proceedings

The standard of due process in administrative proceedings is more flexible and less formal than in judicial proceedings. In the case of Ang Tibay v. Court of Industrial Relations (G.R. No. 46496, February 27, 1940), the Philippine Supreme Court set forth the minimum due process standards applicable to administrative bodies, which have become known as the Ang Tibay Doctrine. The essential requirements of due process in administrative proceedings as articulated in Ang Tibay are:

The right to a hearing: This includes the right to present one’s case and submit evidence.
The tribunal must consider the evidence presented: The tribunal must evaluate and weigh the evidence submitted.
The decision must be supported by evidence: The ruling must be grounded on substantial evidence that reasonably supports the decision.
The decision must be rendered by an impartial tribunal: A neutral and unbiased tribunal must decide the case.
There must be some evidence to support the tribunal’s findings: The decision should not be arbitrary but based on factual evidence presented in the case.
The decision must be clear and definitive: The parties should be informed of the specific findings and rationale of the tribunal.
The tribunal should act within its jurisdiction and authority: Administrative agencies must act within the scope of their granted powers.

4. Doctrine of Exhaustion of Administrative Remedies

Before a party can seek judicial intervention, the doctrine of exhaustion of administrative remedies requires that all administrative processes must first be completed. This doctrine upholds the principle that agencies should be given the opportunity to correct any errors or address grievances internally before court intervention is sought. Exceptions to this doctrine include cases where:

A pure question of law is involved.
The administrative remedy is inadequate or insufficient.
The agency acts with patent illegality or beyond its jurisdiction.
Immediate judicial intervention is necessary to prevent irreparable injury.
There is unreasonable delay or the administrative remedy is futile.

Failure to comply with the exhaustion of administrative remedies may result in the dismissal of the case for being premature.

5. Judicial Review of Administrative Decisions

Administrative agencies’ quasi-judicial decisions are generally subject to judicial review by the courts. However, such review is limited, and courts typically do not re-examine the factual findings of administrative agencies, provided that substantial evidence supports the findings. The courts primarily examine whether:

Due process was observed.
The decision was made within the scope of the agency’s authority.
The decision was supported by substantial evidence.
The decision was not tainted by grave abuse of discretion.

Conclusion

Administrative due process ensures fairness and protection of rights in the exercise of quasi-judicial powers by administrative agencies. While administrative proceedings are more flexible than judicial proceedings, the fundamental requirements of notice, the opportunity to be heard, an impartial tribunal, and a decision based on evidence remain essential components. These principles ensure that the rights of individuals are protected while allowing administrative agencies to effectively perform their adjudicatory functions.