Title
Arroyo vs. Court of Appeals
Case
G.R. No. 202860
Decision Date
Apr 10, 2019
A reorganization under R.A. No. 8371 led to Ulysses Brito's temporary appointment as Regional Director. Brito filed a quo warranto petition against Lee Arroyo, claiming security of tenure. The CA initially reinstated Brito, but the Supreme Court later ruled that Brito's falsification of academic records disqualified him, nullifying the CA's decision and dismissing the petition.
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Case Digest (G.R. No. 202860)

Facts:

Background of the Case

This case arose from the enactment of Republic Act (R.A.) No. 8371, also known as "The Indigenous Peoples' Rights Act of 1997," which led to the reorganization of two offices: the Office for Northern Cultural Communities (ONCC) and the Office of Southern Cultural Communities (OSCC). These offices were merged to form the National Commission on Indigenous Peoples (NCIP), with several sub-offices created under it. The reorganization phased out certain positions, including Staff Directors, Bureau Directors, Deputy Executive Directors, and Executive Directors, except for Regional Directors and below.

Appointment of Ulysses A. Brito

Ulysses A. Brito, who was the Regional Director for Region V of the OSCC, was temporarily appointed to the same position under the NCIP Executive Director's Memorandum Order No. 01-98 dated May 23, 1998. On August 31, 2000, Lee T. Arroyo was appointed as the Regional Director of Region V, replacing Brito.

Quo Warranto Petition

Brito, along with other individuals, filed a petition for quo warranto before the Court of Appeals (CA) challenging Arroyo's appointment. Brito argued that he had a right to security of tenure under R.A. No. 6656 and that Arroyo lacked the required Career Executive Service (CES) eligibility for the position. Arroyo countered that Brito's appointment was temporary and that he lacked the qualifications to be a Regional Director.

CA Decision

On August 30, 2004, the CA partially granted the quo warranto petition, reinstating Brito and another petitioner, Amador P. Batay-an, to their former positions as Regional Directors. The CA held that the positions of Regional Directors were not phased out under R.A. No. 8371 and that Brito, who held a Career Executive Service Officer (CESO) Rank III eligibility, was qualified for the position.

Subsequent Developments

Arroyo filed a motion for reconsideration, arguing that Brito falsified his bachelor's degree, which was a requirement for the position. She attached a decision from the Office of the President (OP) finding Brito guilty of dishonesty and falsification of official documents, resulting in his dismissal from government service. The CA denied Arroyo's motion, and Brito moved for the execution of the CA's decision.

CA's Grant of Execution

On December 7, 2010, the CA granted Brito's motion for execution, ruling that the August 30, 2004 decision had become final and executory. Arroyo filed a motion for reconsideration, which was denied on June 8, 2012. The CA found that Brito had appealed the OP's decision, and thus, the dismissal was not yet final.

Issue:

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Ruling:

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Ratio:

  1. Supervening Events and Immutability of Judgments: The Court held that while judgments generally become final and executory, exceptions exist when supervening events render execution unjust or inequitable. The OP's decision finding Brito guilty of falsification was such a supervening event, as it directly affected Brito's qualifications and right to hold office.
  2. Qualifications for Public Office: The Court emphasized that a bachelor's degree is a fundamental requirement for the position of Regional Director. Brito's falsification of his academic records disqualified him from holding the position, and thus, he could not challenge Arroyo's appointment.
  3. De Facto Officer Doctrine: The Court noted that while Brito's actions as a Regional Director would be valid under the de facto officer doctrine, he could not retain the salaries and emoluments he received during his tenure due to the lack of good faith. He was required to account for these amounts to Arroyo.

Conclusion:

The Supreme Court nullified the CA's resolutions granting the execution of its August 30, 2004 decision and dismissed the quo warranto petition against Arroyo. Brito was directed to account for the salaries and emoluments he received as a de facto Regional Director.


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