Facts:

The case involves Jerrybelle L. Bunsay and 16 other petitioners against the Civil Service Commission (CSC) and the City of Bacolod. The events leading to the case began when the CSC-Field Office in Bacolod City disapproved the promotional appointments of 59 employees, including the petitioners, to various positions in the local government. The CSC Regional Office in Iloilo City upheld this disapproval. However, upon appeal, the CSC issued Resolutions No. 01-0414, No. 01-0415, and No. 01-0416 on February 12, 2001, which validated the promotional appointments but did not provide for backwages. Consequently, 22 of the appointees, including the petitioners, filed a request for back pay, which was denied by the CSC in Resolution No. 01-0872 dated May 3, 2001. The petitioners then filed a Motion for Reconsideration, which was partially granted in Resolution No. 02-0016 dated January 3, 2002, allowing some employees to receive backwages while denying others, including the petitioner...

Facts:

Background on Appointments and Initial Disapproval

• Fifty-nine employees were slated for promotional appointments to various positions in Bacolod City; however, these appointments were initially disapproved by both the CSC-Field Office in Bacolod City and the CSC Regional Office in Iloilo City.
• On appeal, the Civil Service Commission (CSC) upheld the validity of the appointments via resolutions issued on February 12, 2001, though these resolutions did not provide for the payment of backwages.

Request for Backwages and Subsequent CSC Actions

• Out of the 59 appointees, 22 filed a request for backwages when the approved resolutions did not include such payments.
• The CSC denied the request for backwages in Resolution No. 01-0872 dated May 3, 2001, strictly applying the "no work, no pay" principle.
• A Motion for Reconsideration was later filed by most of the appointees (except one) and additional parties joined the appeal concerning their promotional appointments.
• The CSC partially granted the motion in Resolution No. 02-0016 dated January 3, 2002 by:
• Entitling some appointees to receive backwages based on the dates of their appointments and documented service.
• Denying backwages for others due to a lack of evidence showing actual rendered service or due to prior receipt of such payments.

Proceedings Before the Court of Appeals (CA)

• Seventeen petitioners (employees whose backwage claims were either partly or wholly denied) filed a Petition for Review under Rule 43 of the Rules of Court against the decisions of the CSC.
• The Court of Appeals dismissed the petition outright in its February 22, 2002 resolution on technical grounds, citing:
• The failure to include required attachments, such as a copy of CSC Resolution No. 01-0872 and the motion for reconsideration.
• The absence of a required explanation regarding the non-use of personal service upon the respondents.
• A subsequent Motion for Reconsideration filed with the CA was likewise denied in the resolution dated April 16, 2002.

Allegations and Arguments of the Petitioners

• Petitioners argued that the CA had gravely abused its discretion by dismissing their appeal on minor and harmless technical grounds rather than on the merits of their claims.
• They asserted that the proper course was to review the merits of their case regarding the entitlement to backwages, rather than dismissing it for procedural technicalities.
• Petitioners also contended that the differential treatment—granting backwages to some while denying others—violated the equal protection clause, asserting that their inability to render work was due to factors beyond their control.

Respondents’ Positions and Evidentiary Considerations

• The public respondent CSC defended its strict application of the "no work, no pay" policy, emphasizing that backwages are only due for services actually or constructively rendered.
• The City of Bacolod, listed as a respondent, indicated an inability to prepare a memorandum due to insufficient knowledge of the facts.
• Petitioners submitted personnel service records which might demonstrate that they rendered work continuously from the issuance of their appointments up to the CSC’s approval, although the CA dismissed the appeal before fully considering such evidence.
• Numerous factual questions, such as whether petitioners were reverted to their original positions and paid corresponding salaries after disapproval, remain unresolved.

Issue:

Procedural and Substantive Adjudication

• Whether the CA improperly dismissed the petition on technical grounds (missing attachments and procedural lapses) without addressing the merits of the petitioners’ claims for backwages.
• Whether the dismissal constituted a grave abuse of discretion by denying petitioners the opportunity for full adjudication on the substantial issues.

Entitlement to Backwages

• Whether petitioners are entitled to payment of backwages given that their appointments, though initially disapproved, remained effective pending appeal.
• Whether the evidence submitted, particularly the service records, sufficiently demonstrates that petitioners rendered work during the period in question, thereby justifying the backwages.

Equal Protection and Differential Treatment

• Whether the differential treatment—granting backwages only on the basis of actual service rendered—violates the equal protection clause, especially when petitioners argue they were prevented from working by factors beyond their control.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)