G.R. No. 223073 - PJ Lhuillier, Inc. vs. Camacho

The petition for review on certiorari was filed by the Civil Service Commission (CSC) to set aside the decisions rendered by the Court of Appeals in CA-G.R. SP No. 100452.
The CSC previously issued a Decision (dated May 25, 2005) and two Resolutions (dated December 20, 2006, and August 1, 2007) in Administrative Case No. 00-12-027, which found respondent Herminigildo L. Andal guilty of dishonesty and imposed his dismissal with accessory penalties.

Respondent, holding the position of Security Guard II in the Sandiganbayan, filed an application on January 24, 2000, to take the Career Service Professional Examination-Computer Assisted Test (CSPE-CAT) and was admitted to take the examination.
The examination results indicated that respondent passed with a rating of 81.03%.

On January 25, 2000, Arlene S. Vito presented a handwritten authorization, allegedly signed by respondent, claiming to have been authorized to secure the examination results.
Verification against the Picture Seat Plan and the respondent’s identification card revealed dissimilarities in facial features, prompting Bella A. Mitra, Officer-in-Charge of the Examination, Placement and Services Division (EPSD) of CSC-NCR, to issue a memorandum on the alleged “impersonation.”
The matter was referred to the Legal Affairs Division of the CSC-NCR for a fact-finding investigation.

On November 29, 2000, the CSC-NCR formally charged respondent with dishonesty after discrepancies were noted in the identification documents (photographs and signatures).
Several formal investigation hearings were scheduled (June 4, 2001; November 21, 2001; February 5, 2002; and July 10, 2002) but respondent failed to attend, thereby being deemed to have waived his right to present his defense.
On August 5, 2005, the CSC-NCR rendered judgment finding respondent guilty and imposed the penalty of dismissal from service.

Respondent appealed the CSC decision, but the CSC later dismissed his appeal as reflected in Resolution No. 062255 dated December 20, 2006, and the motion for reconsideration was denied in Resolution No. 071493 dated August 1, 2007.
The respondent further elevated the case to the Court of Appeals on a petition for review under Rule 43.
On September 22, 2008, the Court of Appeals reversed the CSC resolutions, set aside the earlier decisions, and held that the CSC had encroached upon the Supreme Court's jurisdiction over court personnel by trying the administrative case against a judicial employee.
The CSC filed a motion for reconsideration before the Court of Appeals, which was denied on December 2, 2008.

Whether the Civil Service Commission has disciplinary jurisdiction to try and decide administrative cases against personnel in the judiciary.
Whether the CSC’s exercise of disciplinary power over respondent, a court employee, violates the constitutional provision that grants the Supreme Court administrative supervision over court personnel.