Types of Due Process
1. Substantive Due Process:
Substantive due process is a constitutional safeguard that protects individuals from arbitrary or unjust government actions that affect their life, liberty, or property. It requires that laws or actions must have a legitimate public interest and cannot be unreasonable or oppressive.
This principle ensures that the government acts within the limits of fairness, preventing discriminatory laws or practices that could violate fundamental rights. Substantive due process is critical in preserving justice, equality, and liberty, forming the foundation for a society that respects individual rights and human dignity.
2. Procedural Due Process:
Procedural due process ensures that individuals are treated fairly when their life, liberty, or property is at stake. It guarantees that a person must be given notice of the charges or accusations against them and an opportunity to respond.
This includes the right to be heard in a neutral and unbiased forum, ensuring that decisions are made based on evidence and that the individual has a fair chance to present their case.
It protects individuals from arbitrary government action and ensures justice and fairness in legal proceedings.
Substantive Due Process
Substantive due process in the Philippines is enshrined in the Constitution under the Bill of Rights, specifically in the due process clauses. It ensures that laws and government actions affecting a person’s life, liberty, or property must not only follow fair procedures (procedural due process) but also be reasonable, just, and in line with the values of justice and fairness.
This right protects against laws that are arbitrary or oppressive. For instance, laws that discriminate or infringe on fundamental freedoms such as the right to privacy, freedom of speech, or the right to own property must meet the standards of substantive due process. It guards against laws or actions that are unjust or violate an individual’s core rights.
In essence, substantive due process mandates that the government’s exercise of power must be grounded in reason and necessity, and that the impact on individual rights must align with society’s core values. It is crucial in protecting the dignity of individuals and ensuring that the government does not act beyond its just authority. It prevents the enactment of laws that undermine justice or that disproportionately harm certain groups without adequate justification.
This principle has been interpreted by the Philippine courts to include rights that are not specifically listed in the Constitution but are seen as fundamental to human dignity and fairness. These rights, such as the right to privacy, the right to marry, and the right to family life, form a significant part of substantive due process protections in the Philippines. Through this, the courts ensure that any laws or government actions must be scrutinized to ensure they are not just procedurally fair, but also substantively just.
Makalintal v. COMELEC (G.R. No. 263590, June 27, 2023)
Makalintal filed a petition against the Commission on Elections (COMELEC) for allegedly depriving him of his right to participate in an electoral process due to a flawed disqualification ruling.
The Supreme Court ruled that concerning substantive due process, it requires the concurrence of two requisites, namely:
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1. the interests of the public generally, as distinguished from those of a particular class, require the interference of the State, referred to as the lawful subject; and
​2. the means employed are reasonably necessary for the attainment of the object sought to be accomplished and not unduly arbitrary or oppressive upon individuals, referred to as the lawful method.139
In the determination of whether the two requisites of substantial due process exist, case law has developed three levels of scrutiny depending on the rights affected, including the level of constitutional protection accorded thereby and the degree of the law's interference with said rights, and the gravity of the governmental objective sought through the law. These are the strict scrutiny, the intermediate scrutiny, and the rational basis tests.
Notably pervading these levels of scrutiny are the basic requirements of legitimate government interest or purpose and the reasonable necessity of the means employed to attain the government interest.
These requisites correspond to the lawful subject and lawful means requisites of the substantive aspect of the due process clause and therefore form the core of any valid legislative enactment. Regardless of the level of scrutiny employed, the absence of either or both of these requisites renders a statute unconstitutional for violation of the due process clause.
Issue:
Whether the actions of the COMELEC violated the petitioner’s substantive due process rights.
Ruling:
The Supreme Court ruled that the COMELEC’s actions were unconstitutional, emphasizing the importance of substantive due process in ensuring fairness and justice. It held that the COMELEC must apply laws consistently and justly, protecting an individual’s right to be heard and to participate in public processes.
Significance:
This case underscores that government actions must not only follow procedural fairness but also be just, reasonable, and not arbitrarily affect individuals’ fundamental rights.
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Republic of the Philippines v. Maria Basa Express Jeepney Operators and Drivers Association, Inc. (G.R. No. 206486, August 16, 2022)
The Republic of the Philippines, through the Land Transportation Franchising and Regulatory Board (LTFRB), challenged the issuance of a franchise to the Maria Basa Express Jeepney Operators and Drivers Association, Inc. (MBEJODA) based on regulatory violations.
Issue: Whether the grant of a franchise to MBEJODA violated substantive due process by depriving them of their right to a fair opportunity to address the allegations.
Ruling: The Supreme Court ruled that MBEJODA’s right to due process was violated. The Court emphasized the importance of substantive due process, which requires government actions to be based on fairness, reasonableness, and adherence to established legal principles. The decision ensured that governmental actions are not arbitrary and that all parties are afforded a reasonable opportunity to contest adverse actions impacting their rights.
Significance: The case highlights how substantive due process safeguards individuals or entities from arbitrary government decisions that may infringe on their rights, ensuring fair and just treatment.
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Philippine Stock Exchange, Inc. v. Secretary of Finance (G.R. No. 213860, July 5, 2022)
The Philippine Stock Exchange (PSE) contested the imposition of a 0.5% stock transaction tax on trades in the securities market, asserting that it violated substantive due process by being unreasonable and excessive.
Issue: Whether the imposition of the tax violated the constitutional right to substantive due process due to arbitrariness.
Ruling: The Supreme Court ruled that the tax did not violate substantive due process. The Court emphasized that laws and government actions must serve a legitimate public interest and be reasonable, fair, and just. The tax was considered a legitimate exercise of legislative power in line with public policy goals.
Significance: The case reaffirms that government actions, including taxation, must adhere to principles of fairness and reasonableness, ensuring that they are not arbitrary or oppressive, thus upholding substantive due process.
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Lee v. City of Olongapo (G.R. No. 246201, December 7, 2022)
Lee challenged the local ordinance passed by the City of Olongapo, which imposed additional taxes on his business. He argued that the ordinance violated substantive due process, claiming that the tax was arbitrary, excessive, and lacked a clear, reasonable basis.
Issue: Whether the imposition of the additional taxes by the City of Olongapo violated the constitutional right to substantive due process.
Ruling: The Supreme Court upheld the validity of the tax, stating that it was a legitimate exercise of the city’s taxing power. The Court emphasized that substantive due process is not violated as long as the tax is reasonable and serves a legitimate public purpose.
Significance: The case highlights that laws and governmental actions are valid under substantive due process if they are reasonable, do not result in arbitrary outcomes, and align with legitimate public interests.
Procedural Due Process
Procedural Due Process under the Philippine Constitution ensures that individuals are given fair procedures before the government deprives them of life, liberty, or property.
Procedural due process focuses on the manner in which the government acts, ensuring that legal proceedings are conducted fairly and that individuals are provided a meaningful opportunity to defend their rights.
Key Elements of Procedural Due Process
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1. Notice
Notice refers to the requirement that a person must be informed in advance of the government action or legal proceeding that may affect their rights. This ensures that individuals are aware of the charges or claims against them, the nature of the proceedings, and any potential consequences.
The notice must be timely and adequate, providing enough detail so that the affected party has a reasonable opportunity to prepare a defense or respond.
2. Hearing
Hearing is the opportunity given to a person to present their case or defense before an impartial authority, whether it be a court or an administrative body. This element guarantees that individuals can be heard before any adverse action is taken against them.
It also implies that individuals must be given the chance to present evidence, question witnesses, and offer arguments in their defense.
The hearing must be fair and conducted by a neutral decision-maker.
3. Impartial Tribunal
Procedural due process requires that the body or individual deciding the case must be impartial and neutral, free from bias or any interest in the outcome.
Judicial independence is a key requirement, meaning that the court or tribunal must not be influenced by any party to the case or by outside pressure.
Decisions must be based solely on the evidence presented and the law applicable to the case.
4. Right to Counsel
In many cases, procedural due process includes the right to be represented by counsel, especially in criminal proceedings. An individual has the right to engage the services of a lawyer to help defend their rights, and in certain circumstances, the government may even be required to provide legal assistance.
5. Right to Present Evidence
A person facing deprivation of life, liberty, or property must be allowed to present evidence in support of their case. This right includes the ability to submit documents, call witnesses, and challenge the evidence presented by the other party.
This ensures that the decision will be based on the merits of the case rather than arbitrary or unsupported claims.
6. Notice of Decision
The decision or ruling made by the court or tribunal must be communicated to the affected party, and the reasons for the decision must be stated. This allows the individual to understand how the case was resolved and, if necessary, to file an appeal or seek other remedies.
Applications of Procedural Due Process
1. Judicial Proceedings
In court trials, whether criminal or civil, procedural due process ensures that defendants receive notice of the charges, the opportunity for a public trial, the right to present a defense, and an impartial judge or jury to decide the case.
In criminal cases, this also includes safeguards like the right to confront witnesses, the right to remain silent, and the right to cross-examine evidence presented by the prosecution.
2. Administrative Proceedings
The principles of procedural due process also apply to proceedings conducted by administrative agencies. Individuals affected by administrative actions (such as the denial of a license, the imposition of penalties, or the taking of property) are entitled to notice and a fair hearing.
Administrative due process requires that decisions made by agencies are supported by substantial evidence and are rendered in a manner consistent with the law.
The ruling must be based on the facts and law applicable to the case and not on arbitrary or capricious grounds.
3. Disciplinary Proceedings
In employment, schools, and other settings, procedural due process applies to disciplinary proceedings. For instance, an employee facing termination or a student facing suspension must be informed of the accusations and given the chance to respond.
The disciplinary body must be neutral and base its decision on the evidence and law.
Exceptions to Procedural Due Process
While procedural due process is a constitutional right, there are certain instances where exceptions or modifications may be allowed:
1. Summary Proceedings
In some cases, especially those involving public welfare, taxes, or public health, the government may conduct summary proceedings that require minimal or no formal notice and hearing. However, these summary actions must still be subject to judicial review afterward to ensure fairness.
2. Emergency Situations
During times of emergency (e.g., martial law, public health crises), the government may act swiftly and without the usual procedural safeguards to protect public welfare or national security. However, such actions remain subject to judicial scrutiny to ensure that rights are not unduly violated.
Landmark case on due process in a Labor law case
Ang Tibay v. CIR (G.R. No. 46496, February 27, 1940)
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Ang Tibay, a leather company owned by Teodoro Toribio, dismissed several workers for alleged misconduct and labor violations. The workers filed a case for illegal dismissal before the Court of Industrial Relations (CIR), claiming that they were terminated without just cause. The CIR ruled in favor of the workers, ordering their reinstatement and payment of back wages.
Toribio, on behalf of Ang Tibay, filed a petition for review before the Supreme Court, questioning the CIR’s decision. He argued that the decision lacked sufficient evidence and that the CIR violated due process in handling the case.
Issues:
1. Was due process followed in the proceedings before the CIR?
2. Is there substantial evidence to support the decision of the CIR?
Ruling:
The Supreme Court ruled in favor of Ang Tibay, emphasizing that procedural due process must be observed in administrative and quasi-judicial proceedings, including those before the CIR.
1. Due Process in Administrative Proceedings:
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The Court established that due process must be respected not only in judicial but also in administrative and quasi-judicial proceedings. It set forth seven essential requirements of due process in administrative proceedings, which have since been known as the “Ang Tibay Doctrine”:
1. Right to a hearing: Parties must be given an opportunity to present their case and evidence.
2. Consideration of evidence: The decision must be based on the evidence presented by the parties.
3. Evidence must be substantial: There must be enough relevant evidence to support the decision.
4. Decision based on evidence presented at the hearing: The decision must rely on the evidence and facts presented during the hearing.
5. The tribunal must act independently: The decision-making body must exercise independent judgment and not be influenced by external pressures.
6. Decision rendered must be certain: The ruling must be definite and final, without ambiguity or uncertainty.
7. The court or tribunal must act on the law: Decisions must be based on existing legal standards and principles.
2. Substantial Evidence:
The Court ruled that substantial evidence must support the findings of the CIR. It emphasized that while the CIR has broad powers in handling labor disputes, it must follow the basic principles of fairness and justice. The decision must be supported by facts presented during the hearing, and the workers’ claims must be proven by substantial evidence.
3. Importance of Procedural Due Process:
The Supreme Court emphasized that procedural due process is a fundamental right, and any decision rendered without complying with due process is void. While the CIR was created to promote social justice and protect labor rights, it cannot disregard the basic requirements of due process. The Court remanded the case back to the CIR to ensure that due process was observed and that both parties were given a fair opportunity to present their cases.
Significance:
The Ang Tibay Doctrine laid down the seven cardinal primary rights constituting due process in administrative and quasi-judicial proceedings in the Philippines. This case serves as a cornerstone for ensuring that administrative bodies, such as the CIR, follow fair procedures in deciding cases. It underscores that even in labor disputes, where social justice plays a significant role, the constitutional guarantee of due process must be upheld.
Disposition:
The Supreme Court remanded the case to the CIR to hold another hearing, ensuring that both parties are given the opportunity to present their evidence and that due process is fully observed.
Key Takeaways:
Ang Tibay establishes the importance of procedural due process in administrative proceedings, ensuring that decisions are fair and just.
The case highlights the need for administrative bodies to base their decisions on substantial evidence and to follow proper procedures in resolving disputes.
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Procedural due process in an Election Law case
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Villanueva v. Commission on Elections, et al.
G.R. No. 260116, July 11, 2023
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Petitioner Crisanto Villanueva was a candidate for mayor in the 2022 local elections. The Commission on Elections (COMELEC) Law Department filed a petition to disqualify him based on allegations of vote-buying and other election offenses. Villanueva contested the petition, arguing that he was not properly notified of the accusations and that his right to a fair hearing was violated. He claimed that the COMELEC had deprived him of the opportunity to defend himself, thus violating his constitutional right to procedural due process.
The COMELEC First Division ruled in favor of the disqualification, which was subsequently affirmed by the COMELEC en banc. Villanueva appealed the decision before the Supreme Court, raising the issue of whether his right to procedural due process had been violated in the proceedings.
Issue:
Did the COMELEC violate Villanueva’s right to procedural due process by not giving him sufficient notice and the opportunity to be heard?
Ruling:
The Supreme Court ruled in favor of Villanueva and found that the COMELEC had indeed violated his right to procedural due process.
Ratio Decidendi:
1. Right to Notice and Hearing:
The Court reiterated that the right to procedural due process involves both notice and the opportunity to be heard. In this case, Villanueva was not properly notified of the specific charges against him, nor was he given an adequate opportunity to present his side and defend himself during the proceedings before the COMELEC. The Court held that these deficiencies amounted to a violation of his constitutional right to due process.
2. Notice Must Be Adequate:
The Court stressed that the notice provided must be clear, timely, and sufficient to inform the individual of the nature of the accusations against them. In this case, the notice given to Villanueva lacked sufficient details regarding the specific acts constituting the alleged vote-buying, which undermined his ability to prepare a defense.
3. Hearing Requirement:
Procedural due process also requires a fair hearing where the affected party can present evidence, call witnesses, and cross-examine the opposing party’s evidence. The COMELEC’s proceedings were found to be lacking in this regard, as Villanueva was not afforded a meaningful opportunity to be heard.
4. Substantial Compliance:
The Court acknowledged that strict adherence to formal rules of procedure is not always required, but there must still be substantial compliance with the requirements of due process. In Villanueva’s case, the lack of proper notice and an opportunity to be heard amounted to a failure to meet even the minimal standards of due process.
5. Consequences of Procedural Due Process Violations:
Since the violation of procedural due process rights is considered a grave error, the COMELEC’s decision to disqualify Villanueva was invalidated. The Court emphasized that the constitutional guarantee of due process must always be observed in both judicial and administrative proceedings.
Disposition:
The Supreme Court reversed the COMELEC’s decision and ruled that Villanueva’s disqualification from running for public office was void due to the violation of his right to procedural due process.
Significance:
This case emphasizes the importance of upholding procedural due process, particularly in election-related matters where an individual’s right to participate in the democratic process is at stake.
It also reiterates that the government, through its agencies like the COMELEC, must ensure that affected individuals are given proper notice and the opportunity to be heard before any adverse action is taken against them.
The ruling serves as a reminder that procedural due process is a fundamental right that cannot be disregarded, even in administrative proceedings.
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Due process in a Family Law case
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AAA261422, a Minor and Represented by YYY261422 v. XXX261422
G.R. No. 261422 (Formerly UDK-17206), November 13, 2023
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The petitioner, AAA261422, a minor represented by YYY261422 (the guardian), filed a petition against XXX261422 (the respondent), involving a family law issue, where AAA sought certain reliefs concerning the respondent’s actions.
The case was initially dismissed by the lower court on procedural grounds, particularly due to the alleged lack of proper notice given to the respondent. The petitioner argued that the court’s dismissal deprived them of a fair trial and failed to consider the merits of the case.
The issue raised before the Supreme Court was whether the dismissal of the case by the lower court, based on procedural grounds, violated the petitioner’s right to due process.
Issues:
1. Was the dismissal of the case on procedural grounds a violation of the petitioner’s right to due process?
2. Did the lower court fail to provide an opportunity for the petitioner to present their case on the merits?
Ruling:
The Supreme Court ruled in favor of the petitioner, AAA261422, and emphasized that the right to due process had been violated in the handling of the case.
1. Due Process in Judicial Proceedings:
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The Court emphasized that the right to due process, both substantive and procedural, is a constitutional guarantee. Procedural due process requires that a party be given notice and an opportunity to be heard before a judgment affecting their rights is rendered. In this case, the lower court’s dismissal of the case without fully addressing the substantive issues deprived the petitioner of this right.
2. Dismissal on Procedural Grounds:
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While courts have the authority to dismiss cases for failure to comply with procedural rules, such dismissal must not be done arbitrarily or in a way that deprives a party of the opportunity to present their case. The Court highlighted that procedural technicalities should not be used as tools to defeat the administration of justice, particularly when the rights of a minor are involved.
3. Substantial Compliance with Due Process:
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The Court held that substantial compliance with the requirements of due process is essential. The lower court’s ruling dismissed the case prematurely without affording the petitioner a chance to argue the merits, thus denying the minor’s right to a fair trial. The Court pointed out that in sensitive cases involving minors, there should be a higher threshold of ensuring that their rights are fully protected.
4. Opportunity to Present Evidence:
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The Court underscored that due process demands not only the right to be notified but also the opportunity to present evidence. In this case, the petitioner was not given an adequate opportunity to present the factual and legal issues central to the case. The Court held that this lack of opportunity was a denial of the petitioner’s right to due process.
5. Importance of Child’s Welfare:
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The Supreme Court stressed that cases involving minors should prioritize the welfare of the child, and procedural technicalities should not overshadow the need for a fair resolution on the merits. The case dismissal, without sufficient examination of the child’s welfare, constituted a failure in upholding the due process rights of the petitioner.
Disposition:
The Supreme Court set aside the lower court’s dismissal of the case and remanded the case for further proceedings, ensuring that the petitioner is given the opportunity to fully present the case on the merits.
Significance:
This case highlights the importance of due process in judicial proceedings, particularly when dealing with the rights of minors. The ruling serves as a reminder that while procedural rules are important, they should not be used to undermine substantive justice. The decision also reinforces the principle that courts must always provide an opportunity for parties to be heard, especially in cases that affect the welfare of vulnerable individuals such as minors.
Summary
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Procedural due process under the Philippine Constitution protects individuals from arbitrary government actions by ensuring fair and just procedures.
It is a safeguard that maintains the balance between the government’s authority to act and the citizens’ rights to be treated fairly.
The consistent application of this doctrine guarantees that justice is not only done but is seen to be done, ensuring that individuals receive their day in court or before an administrative body when their life, liberty, or property is at stake.
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Procedural due process in Labor Law
Suniga, et al. v. Molina, et al.
G.R. No. 229190, November 6, 2023
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Petitioners Suniga, et al. were employees of a company owned by respondents Molina, et al. The petitioners filed a labor complaint for illegal dismissal, claiming that they were terminated without due notice and a valid reason. The respondents countered that the employees were terminated for just cause, citing several instances of misconduct, and claimed that proper procedure was followed.
The Labor Arbiter initially ruled in favor of the petitioners, finding that the respondents failed to observe procedural due process in the termination process. The case was elevated to the Court of Appeals (CA), which reversed the decision, stating that there was substantial compliance with procedural requirements. This prompted the petitioners to elevate the case to the Supreme Court.
Issue:
1. Did the respondents comply with procedural due process in terminating the petitioners’ employment?
2. Was the Court of Appeals correct in ruling that there was substantial compliance with due process requirements?
Ruling:
The Supreme Court ruled in favor of Suniga, et al., reinstating the decision of the Labor Arbiter and finding that the respondents violated procedural due process.
1. Procedural Due Process in Employment Termination:
The Court reiterated the two-notice rule required in cases of termination:
1. The first notice informs the employee of the specific acts or omissions for which dismissal is sought.
2. The second notice provides the employee with the decision of termination after being given the opportunity to be heard.
In this case, the respondents failed to provide sufficient evidence that they complied with the two-notice rule. The Supreme Court emphasized that procedural due process must be strictly observed in employment termination cases to ensure fairness and justice.
2. Substantial Compliance Doctrine:
The Court rejected the Court of Appeals’ finding of substantial compliance. It ruled that substantial compliance does not apply when the core elements of procedural due process are not met.
The Court stressed that “substantial compliance” can only be considered when there has been an honest attempt to follow the legal requirements, but in this case, the failure to issue the proper notices rendered the dismissal procedurally flawed.
3. Due Process as a Constitutional Right:
The Court emphasized that procedural due process is a constitutional right that cannot be disregarded in favor of expediency. Termination of employment is a severe action, and employers are bound to observe both substantive and procedural due process to protect employees from arbitrary dismissal. The rights of employees to security of tenure and the right to be heard must be respected.
4. Right to be Heard:
The petitioners were not given the chance to explain or defend themselves before their termination, which is a fundamental aspect of due process. The Court ruled that even in cases where there may be just cause for termination, failure to observe procedural due process entitles the employee to nominal damages.
Disposition:
The Supreme Court ruled in favor of the petitioners, ordering the respondents to pay nominal damages to Suniga, et al., for the violation of their procedural due process rights. The Labor Arbiter’s decision finding the dismissal illegal was reinstated.
Significance:
This case highlights the strict observance of procedural due process in employment termination cases. The ruling serves as a reminder to employers that even if there is just cause for dismissal, failure to observe the correct procedure, such as providing proper notices and the opportunity to be heard, constitutes a violation of the employee’s constitutional right to due process.
It also underscores the principle that “substantial compliance” cannot remedy the complete disregard for essential procedural requirements.
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Procedural due process in a deportation case
Prescott v. Bureau of Immigration, et al.
G.R. No. 262938, December 5, 2023
Prescott, a foreign national, was ordered by the Bureau of Immigration (BI) to leave the Philippines for overstaying and engaging in unauthorized work. He contended that he was not given the chance to fully present his case and argued that the Bureau violated his right to procedural due process. Prescott had legal documentation in process and claimed that he had communicated with the Bureau about extending his stay. Nevertheless, the BI issued a deportation order.
Issue:
Whether Prescott’s right to procedural due process was violated when the Bureau of Immigration issued the deportation order.
Ruling:
The Supreme Court ruled in favor of Prescott, emphasizing the importance of procedural due process in administrative proceedings. The Court held that even in deportation cases, individuals must be afforded the opportunity to fully present their side and that immigration authorities must follow due process before making decisions that have such significant impacts on an individual’s life.
Ratio:
Procedural due process requires that a person be given the opportunity to be heard and to present evidence in defense of their case. In Prescott’s case, the Court found that the Bureau of Immigration failed to provide him adequate notice and a full hearing before issuing the deportation order.
The lack of proper proceedings and the failure to address Prescott’s attempts to communicate regarding his visa extension constituted a violation of due process rights.
The Court further explained that in any case involving the deprivation of life, liberty, or property, the essential elements of procedural due process must be strictly followed. These elements include:
1. Notice of the nature and cause of the accusation or issue.
2. A reasonable opportunity to be heard and present evidence.
Significance:
This ruling reiterates that the right to due process applies to all individuals, including foreign nationals in administrative proceedings. It highlights that even administrative bodies like the Bureau of Immigration must observe due process in their actions, ensuring that no decision is made arbitrarily or without giving the affected party a chance to defend themselves.
Due Process in Judicial Proceedings
People v. Judge Leviste, G.R. No. 189122, March 17, 2010:
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Impartiality of the Tribunal:
The Court explained that a judge is presumed to be impartial unless proven otherwise. To prove judicial bias, there must be a clear showing that the judge acted with actual bias or prejudice that affected the fairness of the trial. In this case, Leviste failed to substantiate his claims of bias. The Supreme Court ruled that the judge’s remarks were within the bounds of judicial discretion and did not amount to bias that violated due process.
Right to Fair Trial:
Due process ensures that every individual is entitled to a fair trial, which includes the opportunity to be heard and to present evidence. The Court noted that Leviste was given every opportunity to present his defense, and his legal counsel was able to actively participate in the trial. The evidence presented by both sides was thoroughly examined, and the court made its ruling based on the facts and the law.
Judicial Rulings as Basis for Bias:
The Supreme Court clarified that adverse rulings or comments by a judge do not automatically imply bias. The trial court’s adverse rulings on certain motions by Leviste were made in accordance with procedural rules and did not show any predisposition against him.
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Key Takeaways on Due Process:
1. Due process in judicial proceedings demands that a person be given a fair and reasonable opportunity to defend themselves in an impartial court.
2. Judges are presumed to be impartial, and mere adverse rulings do not constitute bias.
3. Procedural due process is satisfied when the accused is given proper notice, the chance to present evidence, and the right to appeal, even if the outcome is unfavorable.