G.R. No. 197634 - Campol vs. Balao-as

Campol served as the Sangguniang Bayan (SB) Secretary for the Municipality of Boliney, Abra since 1999.
He held a permanent position classified under salary grade 24.
His employment with the municipality was affected by the local political transition following the 2004 elections.

In the 2004 elections, Ronald S. Balao-as and Dominador J. Sianen were elected as Mayor and Vice-Mayor, respectively, assuming office in July 2004.
Shortly after taking office, the SB passed a resolution terminating Campol on the ground of being absent without approved leave from August 1, 2004 to September 30, 2004.
The resolution was transmitted to the Sangguniang Panlalawigan (SP), which then referred the matter to CSC-Abra.

CSC-Abra advised that Campol could not be removed since he was protected by the Administrative Code.
The Sangguniang Panlalawigan (SP) and the Department of Interior and Local Government (DILG)-Abra adopted the same position.
Despite these unanimous positions, Vice-Mayor Sianen issued Memorandum Order No. 001, Series of 2004, effectively dropping Campol from the rolls.

Campol initially challenged the memorandum before the CSC-CAR, which ruled in his favor.
Sianen subsequently elevated the case before the Civil Service Commission (CSC), which reversed the CSC-CAR decision and ruled that Campol was properly dropped.
Campol then filed a petition for review under Rule 43 before the Court of Appeals (CA) where he contested:

The allegation of unexcused absences by providing evidence such as his attendance records and salary receipts.
The propriety of his summary dismissal, asserting a deprivation of due process.

The CA reversed the CSC ruling by determining that Campol’s dismissal was without legal basis.
However, the CA refused to order his reinstatement on the ground that since October 2005 he had secured gainful employment with the Public Attorney’s Office (PAO).
Consequently, the CA limited the award of backwages to the period from his dismissal up to October 2005.
Campol, compelled by economic necessity and personal tragedies (including the loss of his wife), argued that the denial of reinstatement and the limited backwages violated prevailing jurisprudence protecting the right to security of tenure.

Campol maintained that his right to be reinstated and to receive full backwages—computed from his illegal dismissal until reinstatement—remained intact, irrespective of any subsequent employment.

Whether Campol is entitled to be reinstated to his former position as SB Secretary despite having accepted subsequent employment.
Whether the award of backwages should be computed from the time of his illegal dismissal until his actual reinstatement, rather than being capped or limited to the period before his new appointment.