Case Digest (G.R. No. 83369)
Facts:
The case involves Pacita J. Baguioro as the petitioner and Hon. Mariano Y. Basa, Jr., the Presiding Judge of Branch 56 of the Regional Trial Court of Negros Occidental, San Carlos City, along with Romeo Espinosa as the respondents. The events leading to this case began prior to April 1982 when both the petitioner and the private respondent were employed in the Schools Division of San Carlos City, Negros Occidental, with the petitioner serving as the Elementary Head Teacher and the private respondent as the Elementary School Principal I. In April 1982, a vacancy for the position of General Education Supervisor I (Music and Arts) arose, and the Division Promotion Board recommended the petitioner for the position. Subsequently, the Regional Promotion Board of Region VI ruled in favor of the petitioner, leading to her appointment by the Regional Director. However, after the private respondent filed a motion for reconsideration, the Regional Director reversed the decision in Novem...
Case Digest (G.R. No. 83369)
Facts:
Background of the Parties
- Prior to April 1982, petitioner Pacita J. Baguioro and private respondent Romeo Espinosa were employed as Elementary Head Teacher and Elementary School Principal I, respectively, in the Schools Division of San Carlos City, Negros Occidental.
- Both were considered for promotion to the position of General Education Supervisor I (Music and Arts) when the position became vacant in April 1982.
Initial Promotion Decision
- On 12 April 1982, the Division Promotion Board recommended petitioner Baguioro for the position.
- In September 1982, the Regional Promotion Board of Region VI of the Ministry of Education, Culture and Sports (MECS) also ruled in favor of Baguioro, and the Regional Director decreed her appointment.
Reversal of Decision
- Private respondent Espinosa moved for reconsideration.
- On 21 November 1983, the Regional Director reversed his decision, declaring Espinosa better qualified and appointing him to the contested position.
Petitioner’s Appeal and Legal Action
- Petitioner Baguioro appealed the decision to the MECS Minister. Due to delays, she filed a petition for Quo Warranto with Mandamus and Damages (Civil Case No. 076) in the Regional Trial Court (RTC) of San Carlos City.
- The RTC dismissed the case on the ground of prescription. Petitioner moved for reconsideration.
Minister Laya’s Intervention
- On 17 April 1985, MECS Minister Jaime C. Laya concurred with a Memorandum-Report from the Complaints Committee, which found the 21 November 1983 decision irregular and recommended reinstating the 23 September 1982 decision favoring Baguioro.
- On 16 May 1985, the Regional Director directed the Schools Division Superintendent to prepare Baguioro’s appointment.
- On 23 October 1985, the RTC denied Baguioro’s motion for reconsideration, ruling the case moot and academic due to Minister Laya’s letter and Baguioro’s assumption of the position.
Private Respondent’s Certiorari Petition
- Espinosa filed a petition for certiorari and prohibition (G.R. No. 73915) with the Supreme Court, challenging Minister Laya’s decision.
- The Supreme Court dismissed the petition on 11 June 1986 for lack of merit, and a motion for reconsideration was denied on 8 April 1987.
Subsequent Quo Warranto Action
- On 28 January 1988, Espinosa filed another Quo Warranto complaint (Civil Case No. 162) in the RTC, seeking to annul Minister Laya’s decision and claiming damages.
- Petitioner Baguioro moved to dismiss the case on grounds of res judicata, prescription, and lack of cause of action.
- The RTC denied the motion to dismiss, prompting Baguioro to file a special civil action for certiorari with the Supreme Court.
Issue:
- Whether the principle of res judicata applies to bar Civil Case No. 162, given the Supreme Court’s dismissal of G.R. No. 73915.
- Whether private respondent Espinosa had exhausted administrative remedies before filing Civil Case No. 162.
- Whether the trial court committed grave abuse of discretion in denying the motion to dismiss Civil Case No. 162.
Ruling:
The Supreme Court granted the petition, set aside the RTC’s order, and dismissed Civil Case No. 162. The Court held:
Res Judicata Applies
- The Supreme Court’s resolution in G.R. No. 73915, which dismissed Espinosa’s petition for lack of merit, constitutes a final judgment on the merits.
- The requisites for res judicata were met: (1) final judgment, (2) jurisdiction over the subject matter and parties, (3) judgment on the merits, and (4) identity of parties, subject matter, and causes of action between G.R. No. 73915 and Civil Case No. 162.
- Espinosa’s attempt to re-litigate the same issues in Civil Case No. 162 constitutes forum-shopping.
Failure to Exhaust Administrative Remedies
- Espinosa failed to exhaust administrative remedies by not appealing Minister Laya’s decision to the Merit Systems Board (now Merit System Protection Board) as required by law.
- The complaint in Civil Case No. 162 failed to state a cause of action due to this failure.
Grave Abuse of Discretion
- The trial court erred in disregarding the Supreme Court’s resolution in G.R. No. 73915 and in failing to apply the principle of res judicata.
- The trial court’s denial of the motion to dismiss was issued with grave abuse of discretion.
Ratio:
- (Unlock)