Title
Cabili vs. Civil Service Commission
Case
G.R. No. 156503
Decision Date
Jun 22, 2006
LWUA-appointed water district directors entitled only to per diems; additional compensation like RATA, bonuses prohibited. CSC jurisdiction upheld; procedural defect non-jurisdictional.
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Case Digest (G.R. No. 156503)

Facts:

  1. Complaint Filed by LEAP: The Local Water Utilities Administration Employees Association for Progress (LEAP), represented by its Chairman, Leonardo C. Cruz, filed a complaint before the Civil Service Commission (CSC) against Camilo P. Cabili (Chairman of the Board of Trustees) and Antonio R. De Vera (Administrator) of the Local Water Utilities Administration (LWUA). The complaint alleged inaction on their letters dated August 26, 1994, and August 29, 1994, regarding violations of Republic Act (R.A.) No. 6713, the "Code of Conduct and Ethical Standards for Public Officials and Employees."

  2. Multiple Directorship Issue: The complaint also sought an investigation into the multiple directorship of LWUA Deputy Administrator Rodolfo de Jesus, who was a member of the board of directors of the Olongapo City Water District. It questioned his entitlement to per diems, representation and transportation allowance (RATA), discretionary fund, and other extraordinary and miscellaneous expenses (EME) in addition to his LWUA compensation.

  3. CSC's Initial Ruling: The CSC, in Resolution No. 95-4073 (July 11, 1995), dismissed the charge for violation of R.A. No. 6713 against Cabili and De Vera. However, it ruled that LWUA officers or employees serving as board members of water districts could only receive per diems, as per Section 13 of Presidential Decree (P.D.) No. 198, and not additional compensation like RATA, EME, rice allowance, medical/dental benefits, uniform allowance, Christmas bonus, cash gift, or productivity incentive bonus.

  4. Motion for Reconsideration: Cabili and De Vera moved for reconsideration, but the CSC denied it in Resolution No. 96-2079 (March 21, 1996). They then appealed to the Court of Appeals (CA).

  5. CA's Decision: The CA, in its July 10, 2001 Decision, ruled that the complaint's lack of verification was a formal, not jurisdictional, defect. It held that LWUA-appointed directors of water districts were entitled to per diem, RATA, and travel allowance but not to rice allowance, medical/dental benefits, Christmas bonus/cash gift, or EME, as these constituted additional compensation.

  6. Motions for Reconsideration Denied: The CA denied the motions for reconsideration filed by the CSC, Cabili, De Vera, and intervenors on December 11, 2002.

  7. Appeals to the Supreme Court: Both the CSC and Cabili/De Vera filed separate appeals before the Supreme Court, which were consolidated.

Issue:

  1. Jurisdiction of the CSC: Whether the CSC has jurisdiction to rule on the legality of granting additional benefits and allowances to LWUA-appointed directors of water districts.

  2. Nature of Compensation: Whether Christmas bonus, cash gift, and productivity incentive bonus constitute additional compensation and should be disallowed.

  3. Compliance with Procedural Rules: Whether the complaint filed by LEAP should have been dismissed for failing to comply with the requirement of being under oath, as per CSC Resolution No. 94-0521.

Ruling:

The Supreme Court ruled as follows:

  1. Jurisdiction of the CSC: The Court affirmed the CSC's jurisdiction over compensation matters of water district personnel, as water districts are government-owned and controlled corporations with original charters under P.D. No. 198.

  2. Prohibition of Additional Compensation: The Court held that directors of water districts are only entitled to per diems, as explicitly stated in Section 13 of P.D. No. 198. All other forms of compensation, including RATA, EME, rice allowance, medical/dental benefits, Christmas bonus, cash gift, and productivity incentive bonus, are prohibited as they constitute additional, double, or indirect compensation.

  3. Procedural Compliance: The Court upheld the CA's ruling that the lack of verification of the complaint was a formal, not jurisdictional, defect and did not warrant dismissal.

Ratio:

  1. Jurisdiction of the CSC: The CSC has the authority to regulate compensation matters of government-owned and controlled corporations, including water districts, as they fall under the civil service system under Article IX-B of the 1987 Constitution.

  2. Prohibition of Additional Compensation: Section 13 of P.D. No. 198 explicitly limits the compensation of water district directors to per diems. Any other form of compensation, such as RATA, EME, or bonuses, is prohibited as it constitutes additional or indirect compensation, which is barred by Section 8, Article IX(B) of the 1987 Constitution unless specifically authorized by law.

  3. Procedural Defects: The requirement for a complaint to be under oath is a formal, not jurisdictional, requirement. The failure to comply with this requirement does not invalidate the complaint or deprive the CSC of jurisdiction.

Conclusion:

The Supreme Court denied the petition of Cabili and De Vera and granted the petition of the CSC. It reinstated CSC Resolution Nos. 95-4073 and 96-2079, affirming that LWUA-appointed directors of water districts are only entitled to per diems and no other forms of compensation.


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