Facts:

The case involves Elenita S. Binay, in her capacity as Mayor of the City of Makati, along with Mario Rodriguez and Priscilla Ferrolino as petitioners, against Emerita Odeaa as the respondent. The events leading to this case began on January 16, 1980, when Emerita Odeaa was employed as a teacher at the Makati Nursery School. She initially served as a contractual employee until July 30, 1992, and subsequently became a casual employee from July 1992 until November 1996. By 1996, she held the position of Clerk 1 and was assigned to the Library Department of Makati High School.

On June 1, 2000, Priscilla Ferrolino, acting as an education consultant, summoned Odeaa to discuss her alleged failure to report for work since November 1999. Odeaa denied the accusations and presented her employee logbook as evidence of her attendance, but Ferrolino dismissed her explanation. The following day, Feliciana A. Rodriguez, Officer-In-Charge of the Timekeeper Section, informed Mario Rodriguez...

Facts:

Employment Background

• Respondent Emerita Odeña was employed as a teacher at the Makati Nursery School on January 16, 1980. She was a contractual employee until July 30, 1992, and a casual employee from July 1992 to November 1996. By 1996, she held the position of Clerk 1 and was detailed at the Library Department of Makati High School.

Alleged Absences

• On June 1, 2000, petitioner Priscilla Ferrolino, an education consultant, called respondent to her office to explain her alleged failure to report for work starting November 1999. Respondent denied the allegations and presented an employee logbook as proof of attendance. However, Ferrolino disregarded her explanation.

Recommendation for Dropping from Rolls

• On June 2, 2000, Feliciana A. Rodriguez, Officer-In-Charge of the Timekeeper Section, wrote to petitioner Mario R. Rodriguez, the City Personnel Officer, recommending that respondent be dropped from the rolls due to her alleged continuous absence since November 10, 1999.

Dropping from Rolls

• On June 8, 2000, petitioner Elenita S. Binay, then Mayor of Makati, issued a memorandum dropping respondent from the rolls effective May 15, 2000, citing her absence without official leave (AWOL) from November 10, 1999. Respondent moved for reconsideration, but it was denied.

Appeal to the Civil Service Commission (CSC)

• Respondent appealed to the CSC, which ruled in her favor on May 29, 2001, finding that the dropping from the rolls was not supported by evidence. The CSC noted that respondent had reported for work during the contested period, and her absences did not amount to a continuous 30-day absence. The CSC also found that her attendance sheet complied with CSC Memorandum Circular No. 21, Series of 1991.

CSC Resolution

• The CSC ordered respondent’s reinstatement with back salaries from the date of separation to actual reinstatement. Petitioners moved for reconsideration, but the CSC denied it on November 18, 2002.

Appeal to the Court of Appeals (CA)

• Petitioners appealed to the CA, which affirmed the CSC’s decision but modified the back salary award, limiting it to a maximum of five years.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Jurisdiction under Rule 45: The Supreme Court’s jurisdiction in petitions for review on certiorari is limited to questions of law. Factual findings of quasi-judicial bodies like the CSC, when affirmed by the CA, are conclusive and not subject to review.
2. Burden of Proof in Dismissal Cases: The burden of proving the validity of dismissal rests on the employer. Petitioners failed to substantiate their claim that respondent was on AWOL for 30 continuous days.
3. Evidence of Attendance: Respondent’s attendance sheets, verified by her supervisor, and her receipt of salaries during the contested period contradicted petitioners’ claim of her absence.
4. Mathematical Impossibility: The CA correctly noted that petitioners’ claim of 400 absences over six months was mathematically impossible.
5. Credibility of Evidence: The CSC and CA correctly gave weight to respondent’s evidence, which was consistent and supported by official records.

Conclusion:

The Supreme Court affirmed the CA’s decision, reinstating respondent with back salaries limited to five years. The Court emphasized that factual findings of lower courts and quasi-judicial bodies, when supported by substantial evidence, are binding and not subject to review.