G.R. No. 258316 - People vs. Norberto Verdadero y Pimentel

Respondent Larry M. Alfonso, Director of the Human Resources Management Department of the Polytechnic University of the Philippines (PUP), was accused of grave misconduct, conduct prejudicial to the best interest of the service, and violation of the Civil Service Law.
The complaint originated from an affidavit-complaint jointly filed on July 6, 2006, by Dr. Zenaida Pia, a Professor IV, and Dindo Emmanuel Bautista, President of Unyon ng mga Kawani sa PUP, alleging that Alfonso abused his authority and improperly included his name in Special Order Nos. 0960 and 1004, thereby authorizing him for extensive overnight services.
The allegations further claimed that Alfonso rendered continuous, excessive work—allegedly working 24 hours daily for several consecutive weeks—resulting in undue earnings under what were described as humanly impossible conditions.

The complainants supported their allegations with various documentary evidences such as the Special Orders, daily time records, payroll registers, copies of check payments, schedules, computations of work hours, and explanations on the nature of overtime and overnight services.
The Civil Service Commission (CSC) received the affidavit-complaint and subsequently, on August 10, 2006, directed Alfonso to submit his counter-affidavit within three days.
In his August 30, 2006 Counter-Affidavit, Alfonso contended that his time records only indicated overnight work on specific dates rather than continuous two-day sessions and explained the entries in his daily time record accordingly.
Despite his explanation, the CSC found his response insufficient and, on October 25, 2006, issued Resolution No. 061821 formally charging him with grave misconduct and conduct prejudicial to the service, while imposing a 90-day preventive suspension.

Alfonso filed an omnibus motion for reconsideration of the preventive suspension order along with a request to change venue from the CSC Central Office to the CSC-National Capital Region (CSC-NCR), asserting that jurisdiction belonged to the regional office pursuant to pertinent CSC regulations.
His first motion was denied; on November 20, 2006, he filed another motion for reconsideration accompanied by a supplemental answer, this time arguing that the CSC lacked jurisdiction, contending that the power to discipline PUP personnel lay exclusively with the PUP Board of Regents under R.A. No. 8292 in relation to R.A. No. 4670.
Without ruling on the motion, on December 11, 2006, CSC Assistant Commissioner Atty. Anicia Marasigan-de Lima issued an order instructing PUP’s Office of the President to implement the preventive suspension order.

Alfonso subsequently sought relief by filing a petition for certiorari and prohibition before the Court of Appeals (CA), which on May 21, 2007, rendered a decision in his favor.
The CA held that:

The CSC’s direct exercise of jurisdiction over the administrative complaint was questionable because the complainants were PUP employees rather than private citizens, and
The proper administrative remedy should have been exhausted by channeling the complaint through the PUP Board of Regents, the composed investigative body under P.D. No. 1341.

The CA also noted that once a remedy within the administrative machinery exists, it must be fully exhausted before any other agency may intervene.

On appeal, the Supreme Court evaluated the jurisdictional issue by focusing on the inherent mandate of the CSC as prescribed by the Constitution and relevant statutory provisions.
The Court underscored that the CSC, as the central personnel agency of the government, has the inherent power to supervise and discipline all government employees—even those employed in government-owned or controlled corporations like PUP.
The Supreme Court also observed that Alfonso’s participation in the CSC proceedings (by filing counter-affidavits and motions for reconsideration) amounted to a submission to CSC’s jurisdiction and precluded him from later contesting that jurisdiction on the grounds of statutory exclusivity claimed by the PUP Board of Regents.

Whether the Civil Service Commission (CSC) possesses the jurisdiction to hear and decide the administrative case filed against Larry M. Alfonso notwithstanding his argument that disciplinary power should be exercised exclusively by the PUP Board of Regents.
Whether Alfonso’s subsequent challenge to the CSC’s jurisdiction is valid given his earlier active participation in CSC proceedings and his submission to its authority.

Whether the doctrine of exhaustion of administrative remedies precludes the CSC from exercising its authority because an alternative administrative channel (i.e., the PUP Board of Regents) exists for handling the complaint.

Whether the existence of special laws and statutory provisions establishing disciplinary committees (like those under R.A. No. 8292 and R.A. No. 4670) limits or negates the CSC’s inherent power to supervise and discipline government employees.