A.C. No. 9334 - Lopez vs. Mata

On August 27, 2001, Chairman Eufemio Domingo of the Presidential Anti-Graft Commission (PAGC) appointed respondent Jose R. Ramirez, Jr. as Executive Assistant III and concurrently designated him as Assistant Accountant.
On September 28, 2001, following Chairman Domingo’s resignation and the succession of petitioner Cesar D. Buenaflor to the chairmanship, Buenaflor terminated Ramirez.
The termination was premised on the allegation that Ramirez’s appointment was personal and confidential—thus, co-terminous with the tenure of the appointing authority—whereas Ramirez contended that his appointment was contractual in nature.

Ramirez filed a complaint in the Regional Trial Court (RTC), Branch 96, Quezon City (Civil Case No. 01-4577-8) to have his dismissal declared null and void.
The petitioner, represented by the Office of the Solicitor General (OSG), raised special defenses, including the argument that Ramirez had not exhausted administrative remedies by not filing a complaint with the Civil Service Commission (CSC).
The RTC rendered judgment on December 28, 2007, in favor of Ramirez, awarding actual, moral, exemplary damages, attorney’s fees, and costs, based on the finding that Buenaflor had failed to prove that Ramirez’s employment was co-terminous with the former chairman’s term.
Buenaflor’s motion for reconsideration at the RTC was denied on September 30, 2008.

The OSG, acting on behalf of Buenaflor, filed a notice of appeal on September 22, 2011, contending that procedural delays (notably in the receipt of the RTC order) should excuse the late filing.
The RTC, relying on its document tracking system, maintained that the pertinent order was received in a timely manner and dismissed the appeal for being filed out-of-time.
In the Court of Appeals (CA), Buenaflor petitioned for certiorari challenging the RTC’s dismissal, alleging technical defects and grave abuse of discretion in retaining jurisdiction over a civil service matter.
The CA issued two resolutions—one on January 31, 2012, dismissing the petition for certiorari on technical grounds, and another on April 24, 2012, denying the motion for reconsideration, despite the petitioner’s claim that procedural defects had been rectified.

The core dispute centers on the proper venue and jurisdiction: whether the RTC has the authority to decide cases involving the termination of a civil servant or whether such cases fall exclusively under the jurisdiction of the Civil Service Commission (CSC).
Ramirez’s complaint sought a judicial determination on the validity of his termination—a matter that the petitioner argued was inherently within the exclusive competence of the CSC.

Ramirez’s complaint detailed his appointment on a contractual basis with a presumed term of one year (subject to renewal) under CSC Memorandum Circular No. 38, and his subsequent dismissal without due process.
The petitioner contended that the RTC’s actions, including its issuance of a judgment and order despite lacking proper jurisdiction, were void from the outset.
Ancillary issues, such as the failure to exhaust administrative remedies and alleged procedural infirmities in petition filings, were also raised by the petitioner throughout the course of litigation.

Whether the RTC had jurisdiction to hear and decide a case involving the termination of a civil servant.
Whether jurisdiction over such personnel actions should be exclusively with the Civil Service Commission (CSC) by virtue of the Constitution and relevant laws.

Whether the filing of Ramirez’s notice of appeal (filed on September 30, 2011) was timely, taking into account the alleged delay in receipt of the RTC’s order.
Whether the procedural defects identified by the CA (such as the absence of required certificates and current PTR details) warranted dismissal of the petition for certiorari.

Whether the CA and the RTC committed grave abuse of discretion by maintaining jurisdiction over a matter that arguably lay outside their competence.
Whether the dismissal of the petition for certiorari was justified despite the petitioner's claims and the evidentiary record.

Whether Ramirez’s termination was legally justified as a co-terminus appointment or conversely, whether it should have continued as a contractual employment subject to renewal.
Whether the legal and factual basis for termination adhered to due process and the principles governing civil service appointments and separations.