In re Letter to Mrs. Maria Coronel, 238 SCRA 619
F: Benito Mapilisan was dismissed by the Supreme Court for dishonestry amounting to gross misconduct occasioned by the loss, while in his custody, of a registered mail letter, the contents of which were pilfered, as the P25,000 bank draft contained therein, eventually found its way for encashment with payee bank, PNB. The contentions of this MFR hinge on the alleged violation of procedural due process by claiming that there was no formal administrative complaint filed against him by either complainant Maria Coronel or the CA nor was there a formal investigation conducted. Accroding to him, the letter complaint of Maria Coronel failed to properly and formally charge the former since the letter complaint was neither suscribed nor sworn to by the complainant.
ISSUE: W/N there was a violation of procedural due process.
HELD: NO Under Sec. 6, Art. VIII of the 1987 Constitution, the Supreme Court shall have administrative supervision over all courts and the personnel thereof. By this power, the Supreme Court can act on a subject complaint, particularly where , as in this case, an investigation thereon had already been conducted and concluded by the CA prior to its referral to SC, with the recommendation that movant be charged with gross negligence.
The complaint, though defective as to form, has been fully substantiated on the basis of the accompanying independent investigation Report and Recommendation submitted to SC. As a matter of fact, the Court even entertains anonymous complaints where the charge can be fully borne out by the evidence offered, or continues proceeding with the administrative case despite withdrawal by complainant of his complaint where an investigation thereto has been made by the Acting Court Administrator prior to the filing of the complaint. Thus, what is given paramount importance by this Court in instances where its power of administrative supervision over court employees is invoked is the substantiation of the complaint rather than its conformity with the formal requirements.