Case Digest (G.R. No. 108031) Core Legal Reasoning Model
Facts:
The case involves Andabai T. Arimao as the petitioner and Saadea P. Taher as the respondent. The pertinent events unfolded in Cotabato City, culminating in a decision dated August 7, 2006. On March 22, 1995, Arimao was appointed as Director II of the Bureau of Non-formal Education under the Department of Education, Culture and Sports in the Autonomous Region in Muslim Mindanao (DECS-ARMM). However, her appointment was contested by Alibai T. Benito, who asserted that it did not undergo the necessary personnel selection board evaluation process. Following this dispute, the Civil Service Commission (CSC) disapproved Arimao's appointment due to insufficient experience required for the role. On May 2, 1996, the CSC affirmed this disapproval and ordered her reversion to her previous position as Education Supervisor II.
Arimao filed a motion for reconsideration, which was denied, leading her to pursue a petition for review with the Court of Appeals. This petition was denied as wel
Case Digest (G.R. No. 108031) Expanded Legal Reasoning Model
Facts:
Appointment and Protest:
- On 22 March 1995, petitioner Andabai T. Arimao was appointed as Director II, Bureau of Non-formal Education, Department of Education, Culture and Sports (DECS-ARMM).
- On 17 July 1995, respondent Saadea P. Taher was appointed Education Supervisor II.
- Petitioner's appointment was protested by Alibai T. Benito, who claimed the appointment did not pass through the personnel selection board. The Civil Service Commission-Field Office (CSC-FO) disapproved petitioner's appointment due to insufficient experience, and she was ordered to revert to her former position of Education Supervisor II.
Study Leave and AWOL Declaration:
- Petitioner applied for and was granted a one-year academic scholarship with pay effective 30 October 1996 as Education Supervisor II.
- Petitioner's motion for reconsideration of the CSC decision was denied, and her petition for review before the Court of Appeals was also denied, becoming final on 17 October 1998.
- Meanwhile, respondent filed a complaint regarding petitioner's absence, leading to petitioner being declared Absent Without Leave (AWOL) and dropped from the payroll on 24 December 1998.
Reinstatement Attempts:
- On 20 July 2000, Acting Regional Governor Matalam ordered petitioner to reassume her position as Education Supervisor II, revoking the AWOL order. However, on 1 August 2000, the same Acting Governor reinstated the AWOL order.
- On 4 August 2000, ARMM Regional Governor Misuari issued a Memorandum ordering petitioner's reinstatement based on CSC Resolution No. 96-3101.
Legal Proceedings:
- Respondent filed a Petition for Prohibition before the Regional Trial Court (RTC) to prevent petitioner's reinstatement, arguing she would suffer irreparable injury.
- The RTC issued a writ of preliminary injunction and later ruled in favor of respondent, holding that the 4 August 2000 Memorandum could not be implemented due to the AWOL order and petitioner's separation from service.
Issues:
- Whether a writ of prohibition lies to enjoin the ARMM Governor's directive to reinstate petitioner despite her being declared AWOL and dropped from the rolls.
- Whether the trial court erred in taking cognizance of the petition for prohibition and whether it violated the doctrine of primary jurisdiction.
- Whether the AWOL order validated respondent's occupancy of the position of Education Supervisor II.
- Who, as between petitioner and respondent, is entitled to the position of Education Supervisor II.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)