Parts of a Notice of Decision in Philippine Administrative Law

I. Overview

In Philippine administrative adjudication, the Decision is the agency’s formal resolution of a case, while the Notice of Decision (NoD) is the transmittal that formally communicates that resolution to the parties, starts the appeal or reconsideration periods, and provides proof that due process by notice has been observed. Many agencies merge these into a single document; others issue a separate NoD with the full Decision attached. Either way, understanding the required parts—and why each part matters—is essential for validity, enforceability, and judicial review.

This article explains (A) the legal foundations that shape content requirements, (B) the parts of the Decision itself (because the NoD often summarizes them), and (C) the parts of the Notice of Decision. It also covers service, finality, execution, drafting standards, and templates you can adapt to specific agencies.

II. Legal Foundations and Standards

Constitutional Due Process (Art. III, Sec. 1). Parties must be heard through notice and opportunity to explain; the Decision must rest on substantial evidence.
Administrative Code of 1987 (Book VII). Core expectations include: decisions must be in writing and must distinctly state the facts and the law on which they are based. Agencies may have charters and procedural rules that add specific form and timing requirements.
Rules of Court (suppletory). When agency rules are silent, courts generally expect analogous observance of fundamentals: proper service, computation of periods, finality, and proof of service.
Data Privacy Act & FOI regime. Agencies should redact sensitive personal information when decisions are posted or released beyond the parties, and ensure lawful basis for sharing.
Ang Tibay line of cases (administrative due process). While best known for standards on evidence and fairness (e.g., substantial evidence, consideration of the whole record), these cases indirectly inform what the Decision must show: findings anchored on evidence, not mere conclusions.

III. Parts of the Decision (for context)

Even when you’re drafting only a NoD, you need to know what the Decision must contain because you will summarize or reference these elements.

Caption/Heading
- Agency name and office
- Case title and docket number
- Nature of the case (e.g., administrative complaint, licensing appeal)
- Sometimes: subject matter tags (e.g., “DISMISSAL FOR CAUSE,” “LICENSE REVOCATION”)
Introduction / Antecedent Facts
- Jurisdictional and procedural background (who filed, when, nature of action)
- Key dates of filings, conferences, hearings
- Matters taken up sua sponte (if any)
Issues Presented
- Clear, numbered issues framed for decision
- If there are procedural issues (jurisdiction, timeliness, mootness), state them distinctly
Standards and Governing Law
- Applicable statutes, rules, circulars
- Standard of proof (typically substantial evidence in admin cases)
- Burden of proof / burden of going forward, as relevant
Discussion / Findings of Fact
- Weigh the evidence; explain credibility determinations
- Address material claims and defenses (silence on material points can be reversible)
Conclusions of Law
- Apply specific provisions to the established facts
- Resolve each framed issue with a clear legal conclusion
Dispositive Portion (Fallo)
- The ordered outcome: dismiss, grant, impose penalty/sanction, direct relief
- Specific directives to parties or agency units for implementation
- Effectivity and whether the decision is immediately executory or stayed by appeal
- Costs/fines/fees and payment instructions, if applicable
Ancillary Matters
- Separate opinions (for collegiate bodies): concurring/dissenting votes
- Voting and quorum certification (if applicable)
- Confidentiality/redaction notes where required
Signatures and Authentication
- Name, position, and wet/secure electronic signature of the authorized official(s)
- Date and place of issuance/promulgation
- Agency seal or security features (if provided by internal protocols)

IV. Parts of the Notice of Decision

A well-constructed NoD achieves three things: it identifies the case and the decision, informs parties of the dispositive outcome and their remedies, and proves service. Whether separate or embedded atop the Decision, it should contain the following parts.

Agency Letterhead / Heading
- Full agency name and office address/contacts
- Optional QR code or URL for verification (if your agency supports it)
Document Title
- “NOTICE OF DECISION” (or “Notice of Resolution/Order”)
- Reference to the specific tribunal/board/division if the agency has multiple levels
Addressee Block
- Full name and address/email of each party and counsel/authorized representative
- Include party designations (Complainant/Respondent, Appellant/Appellee)
Case Identifiers
- Case title and docket number
- Nature of the case
- Date of Decision/Promulgation
Reference to the Decision
- A sentence like: “Please be informed that on [date], the [Agency/Office] promulgated a Decision in [Case No.].”
- State whether the full Decision is attached or provide the secure link/access instructions if served electronically
Dispositive Summary
- A succinct extract of the fallo (not the entire reasoning):
  - e.g., “The complaint is DISMISSED for lack of substantial evidence,” or
  - “Respondent is found GUILTY of Grave Misconduct; penalty: DISMISSAL from the service with forfeiture of benefits and perpetual disqualification, effective upon receipt.”
- If there are specific directives (pay a fine, return items, cease and desist), list them clearly with deadlines.
Executory Nature / Stay
- State if the decision is immediately executory (common in many administrative regimes) or stayed by appeal.
- If partial stays or conditions apply (e.g., need for a supersedeas bond), say so plainly.
Available Remedies
- Motion for Reconsideration (MR): whether allowed, who may file, how many MRs are permitted (often one), filing period (commonly 15 calendar days from receipt unless agency rule states otherwise).
- Appeal: the proper appellate body (e.g., the Department Secretary, a Commission, the Office of the President, or the Court of Appeals via Rule 43), period to appeal (often 15 days from receipt or from denial of MR), mode (notice of appeal, petition), and any fees or bond requirements.
- Clarify where and how to file (physical office, e-mail/e-portal if authorized), and that late filings are out of time.
- Note that filing an MR typically tolls the appeal period only if agency rules so provide; if rules differ, recite the applicable rule.
Computation of Periods
- State the start point (“from receipt of this Notice/Decision”) and handling of weekends/holidays (if last day falls on a non-working day, filing allowed on next working day, unless agency’s e-filing rules say otherwise).
Proof and Mode of Service

Identify the mode of service used for each party (personal, registered mail, courier, authorized email/e-service portal).
Include tracking/reference numbers, email timestamps, and/or acknowledgment of receipt if available.

Enclosures / Attachments

“Encl: Decision dated [date], [#] pages” and other annexes (forms, compliance templates).

Signature/Authority Line

Name and position of the authorized signatory (Clerk of the Commission/Board, Executive Director, Hearing Officer, or Adjudication Division Chief).
Date of issuance of the Notice (which may be different from the Decision date).

Service List (CC:)

Consolidated list of parties, counsels, and internal implementing offices (e.g., Enforcement, Licensing, HR, Finance) that must act on the fallo.

Data Privacy / Confidentiality Footnote (as needed)

Short statement on intended recipients, redactions for public copies, and contact for access concerns.

Page Footer / Control

Pagination (“Page x of y”), document control number, or barcode if your agency uses records management systems.

V. Service, Receipt, Finality, and Entry of Judgment

When periods start: Ordinarily from actual receipt by the party or counsel, evidenced by proof of service. If both are served, the counsel’s receipt governs in contentious practice.
Proof of service: Registry receipts and return cards; courier waybills and delivery confirmations; email headers/server receipts; or personal service acknowledgments. Keep these in the records jacket.
Finality: A decision becomes final and executory upon lapse of the period to seek MR/appeal without such filing, or upon receipt of a denial of a timely MR/appeal if no further remedy exists.
Entry/Certificate of Finality: Many agencies issue a Certificate of Finality and/or Entry of Judgment; note the date, attach proof of lapsed periods, and route to Implementation/Enforcement.
Execution: If immediately executory, the implementing office may proceed even pending MR/appeal, unless a stay is granted by competent authority. The NoD should signal this where applicable.

VI. Drafting and Formatting Best Practices

Clarity over jargon. Use short declarative sentences in the NoD; reserve legal reasoning for the Decision.
Mirror the fallo. The NoD must not alter the dispositive text; quote essential directives verbatim or paraphrase with a clear “subject to the attached Decision.”
One font, one numbering scheme. Keep professional typography, consistent case identifiers, and standardized paragraph numbering.
Accessibility. If using e-service, ensure attachments are OCR-readable and filenames follow agency conventions (e.g., DEC_2025-09-23_CASE-12345.pdf).
Redaction plan. Prepare a public version (with redactions) separate from the parties’ copy, if decisions are posted or disclosed.
Cross-checks. Before release: (1) match case numbers/titles across NoD and Decision; (2) review dates; (3) verify remedies and periods as per agency rules; (4) confirm signatory authority.

VII. Common Pitfalls (and How to Avoid Them)

Missing remedies or wrong periods. Always cite the correct appellate path and deadline in plain language.
Failure to indicate executory status. This breeds confusion and non-compliance; spell it out.
Serving only the party, not counsel. In adversarial settings, service on counsel of record controls.
Ambiguous addresses/emails. Confirm the last notified address on record; reflect any updated contact details from recent filings.
No proof of service on file. Attach or log proof contemporaneously; courts look for this.
Inconsistent dispositive text between Decision and NoD. Keep a strict copy-paste discipline for the outcome language.

VIII. Templates (Adapt as Needed)

A. Notice of Decision (separate transmittal)

[Agency/Office Letterhead] NOTICE OF DECISION

To: [Name of Party/Counsel] [Address/Email]

Case: [Title], [Docket No.] Nature: [e.g., Administrative Complaint for …] Decision Date: [Month Day, Year]

Please be informed that on [Decision Date], the [Agency/Office/Division] promulgated a Decision in the above-entitled case. A copy of the Decision is attached hereto.

Dispositive Summary: [Quote/concise statement of the fallo].

Executory Status: [Immediately executory / Stays upon appeal / Executory upon finality].

Available Remedies:

Motion for Reconsideration: [period, where/how to file, if allowed only once].

Appeal: [proper appellate body, period, mode, fees/bond if any].

Computation of Periods: The period to seek MR or appeal shall be counted from receipt of this Notice/Decision by you or your counsel, as applicable. If the last day falls on a Saturday, Sunday, or legal holiday, filing on the next working day shall be deemed timely, subject to agency e-filing rules.

Mode of Service Used: [Personal / Registered Mail (No. ______) / Courier (WB No. ______) / Authorized E-mail (timestamp ______)].

Enclosures: Decision dated [Date], [x] pages; [other annexes].

Issued on: [Month Day, Year] at [City], Philippines.

Very truly yours,

[Name] [Position/Office]

CC/Service List: [Parties, counsel, implementing units].

B. Proof of Service (attach to the record)

I certify that on [date], a copy of the Notice of Decision and the Decision dated [date] in [Case No.] was served upon: – [Name, Role], at [Address/Email], by [mode]; proof: [RR No./Waybill/Timestamp]. – [Counsel Name], at [Address/Email], by [mode]; proof: [details].

[Name/Signature] [Position] • [Office]

C. Dispositive Portion (for the Decision)

WHEREFORE, premises considered, [outcome]. [Specific directives with deadlines].

SO ORDERED. [Date, Place]

[Authorized Signatory] [Title/Office]

IX. Quick Checklist

Correct caption, case number, and dates
Clear dispositive summary and executory status
Accurate remedies with deadlines and venue
Mode of service identified, with proof attached or logged
Signature by proper authority
Enclosures listed and actually attached
Data privacy and redaction handled appropriately

X. Final Notes

Always align the NoD with the agency’s specific rules (charter, rules of procedure, circulars). Generic periods (often 15 calendar days) are common but not universal.
The NoD is not just a courtesy letter—it is a jurisdictional trigger for appellate timelines and a due-process safeguard. Treat it with the same rigor you apply to the Decision itself.