Title
Bunsay vs. Civil Service Commission
Case
G.R. No. 153188
Decision Date
Aug 14, 2007
Employees' promotional appointments were initially disapproved; SC ruled they are entitled to backwages for actual services rendered, remanding to CA for factual determination.
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Case Digest (G.R. No. 153188)

Facts:

  1. Background of the Case:
    Petitioners are among 59 employees whose promotional appointments to various positions in the local government of Bacolod City were initially disapproved by the Civil Service Commission (CSC) Field Office in Bacolod City and the CSC Regional Office in Iloilo City. On appeal, the CSC upheld the validity of their promotional appointments in Resolutions No. 01-0414, No. 01-0415, and No. 01-0416, all dated February 12, 2001. However, these resolutions did not provide for the payment of backwages.

  2. Request for Backwages:
    Twenty-two (22) of the 59 appointees, including petitioners, filed a request for back pay with the CSC. The CSC denied their request in Resolution No. 01-0872 dated May 3, 2001, citing the "no work, no pay" principle.

  3. Partial Grant of Backwages:
    The CSC partially granted the Motion for Reconsideration in Resolution No. 02-0016 dated January 3, 2002. Some employees were granted backwages based on evidence of actual service rendered, while others, including petitioners, were denied due to lack of evidence.

  4. Appeal to the Court of Appeals (CA):
    Petitioners filed a Petition for Review with the CA, but the CA dismissed the petition on technical grounds, such as the failure to attach required documents and the absence of an explanation for not personally serving the respondents.

  5. Supreme Court Petition:
    Petitioners filed a Petition for Review on Certiorari with the Supreme Court, arguing that the CA gravely abused its discretion by dismissing their appeal on technical grounds and failing to address the merits of their case.

Issue:

  1. Whether the CA committed grave abuse of discretion in dismissing petitioners' appeal based on technical grounds, thereby denying them the opportunity to have their case decided on its merits.
  2. Whether petitioners are entitled to backwages despite the initial disapproval of their promotional appointments.
  3. Whether the CSC's application of the "no work, no pay" principle violated the constitutional guarantee of equal protection of laws.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court ruled in favor of petitioners, holding that they are entitled to backwages based on actual services rendered. However, the exact amount must be determined by the CA after evaluating the evidence. The Court emphasized the importance of deciding cases on their merits and ensuring that procedural lapses do not deprive parties of justice.


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