G.R. No. 102358 March 30, 1993
SPOUSES VICENTE and GLORIA MANALO, petitioners, vs. HON. NIEVES ROLDAN-CONFESOR, in her capacity as Undersecretary of Labor and Employment, JOSE SARMIENTO as POEA Administrator, CAREER PLANNERS SPECIALISTS’ INTERNATIONAL, INC., and SPOUSES VICTOR and ELNORA FERNANDEZ, respondents.

FACTS

Petitioners sued private respondents for illegal exaction, false advertisement, and violation of labor laws. The POEA, in its Order of May 7, 1990, suspended the authority of Career Planners Specialists’ International, Inc. (CAREER) for four months for illegal exaction on two counts, imposed a fine of P40,000.00 (or the suspension in lieu thereof), ordered restitution of P28,714.00 to the petitioners, and meted a fine of P40,000.00 on Filipino Manpower Services, Inc. (FILMAN) for misrepresentation. However, on February 4, 1991, the POEA reversed itself on the penalty for illegal exaction, reasoning that clear and convincing evidence was necessary to justify suspension. The Undersecretary of Labor sustained this reversal, holding that the charge of illegal exaction needed corroborative circumstantial evidence. The Supreme Court, in its Decision of November 19, 1992, set aside the subsequent orders of the Undersecretary and the POEA Resolution, and reinstated the POEA’s original Order of May 7, 1990. The Court held that only substantial evidence, not clear and convincing evidence, was required for administrative findings. Respondents filed motions for reconsideration.

ISSUE

Whether the POEA and the Department of Labor committed grave abuse of discretion in reversing the penalty for illegal exaction against CAREER by requiring a degree of proof higher than substantial evidence.

RULING

The Supreme Court denied the motions for reconsideration. It found that the POEA’s original Order of May 7, 1990, had already found the complainants’ version “more convincing” and that their narration “inspired belief” in the allegation of illegal exaction. The subsequent reversal was not based on a finding that the respondents’ version had become more believable, but on an erroneous escalation of the required degree of proof from substantial evidence to clear and convincing evidence. This constituted grave abuse of discretion. The Court reiterated that in administrative proceedings, only substantial evidence is required, and a credible, convincing testimony of a lone witness can suffice. The Court also noted that the failure of petitioners to state the exact date of payment and their differing versions on how the money was bundled were trivial inconsistencies that did not discredit their testimonies, especially as they were not given a chance to explain them. The Court further held that judicial review is proper when there is grave abuse of discretion, as in this case where the administrative bodies disregarded the law on the required quantum of evidence.