Title
Camus vs. Civil Service Board of Appeals
Case
G.R. No. L-13685
Decision Date
May 31, 1961
The Supreme Court found that unauthorized actions by a Civil Service eligible constituted simple negligence, leading to reinstatement after an initial gross misconduct ruling.
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Case Digest (G.R. No. L-13685)

Facts:

  • Quirico Camus, the petitioner and appellant, was employed as an Administrative Officer at the Bureau of Public Works with an annual salary of P6,000 since January 1, 1951.
  • On September 13, 1952, administrative charges were filed against him for signing applications to import petroleum asphalt without proper authorization.
  • The Import Control Commission approved these applications and issued necessary licenses, but the Bureau of Public Works failed to provide the dollars for importation, causing shipment complications.
  • The Commissioner of Civil Service found Camus guilty of gross misconduct on December 12, 1952, imposing a two-month suspension without pay, considering his long service and clean record.
  • On November 5, 1953, this decision was modified, reinstating him to a lower position with a reduced salary.
  • Camus appealed to the Civil Service Board of Appeals, which affirmed the finding of gross misconduct on January 16, 1956.
  • He then sought judicial review in the Court of First Instance of Manila, arguing his actions were merely an error in judgment, but the lower court dismissed his petition, prompting his appeal.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the Civil Service Board of Appeals erred in finding Camus guilty of gross misconduct, determining his actions constituted simple negligence.
  • The penalty of...(Unlock)

Ratio:

  • The Court noted that both the Commissioner of Civil Service and the Civil Service Board of Appeals found Camus acted under the belief that his actions were authorized and for public benefit, without any ulterior motives or bad faith.
  • Misconduct requires wrongful intention, which was absent in Camus's case; he merely made an error in judgment.
  • The definition of gross misconduct, which includes flagrant or shameful conduct, was not met by Camus's actions.
  • The penalties imposed must a...continue reading

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