G.R. No. 121422 - Cruz y Digma vs. People

In 2005, Cagayan State University (CSU) engaged Dr. Roselle C. Annang as a part-time faculty member through a six‐month service contract.
The service contract expressly stipulated that:

The contract was subsequently renewed five times, amounting to a total engagement period of two years and six months.
Later, following the completion of the series of contracts, Dr. Annang was appointed as Assistant Professor III in a permanent capacity until her retirement in 2012.

In 2013 – after her retirement – Dr. Annang filed a request for the accreditation of her two years and six months of service as a part-time faculty member.
The purpose of the accreditation was to enable her to reach the 15 years of government service required by Section 13 of Republic Act No. 8291 (the Revised Government Insurance Act of 1997), as without such accreditation she would have only 14 years and four months of service.
The request was initially referred by the CSC Regional Office No. II in Tuguegarao City to the CSC Central Office, which ultimately rejected her application.

The CSC Central Office relied on a memorandum circular, emphasizing that services rendered under contracts of service are not considered government service.
In its decision, the CSC stated:

An employee who has already retired may not request for accreditation;
Dr. Annang was not appointed in a manner conferring a traditional employer-employee relationship; and
The pertinent CSC rule clearly holds that services rendered under contracts of service are not eligible to be credited as government service.

Consequently, the CSC dismissed Dr. Annang’s petition for review, affirming its denial of accreditation for the service rendered between June 14, 2005, and December 16, 2007.

The services rendered under the contract of service should be credited as government service for the period from June 14, 2005, to December 16, 2005; and
The CA applied the four-fold test to determine an employer-employee relationship between CSU and Dr. Annang, noting that her work was integral to the university’s primary functions.

There was no necessity for Dr. Annang to be appointed before her service could be accredited; and
The determination of the employer-employee relationship via the four-fold test was appropriate despite contrary stipulations in her contract.

The CSC promptly filed a Motion for Reconsideration, which was denied by the CA through its Resolution.

The petition for review on certiorari was filed by the CSC, seeking to reinstate its original decision which denied the accreditation of Dr. Annang’s service.
The central controversy was whether an individual, having already retired, could request accreditation under the relevant CSC rules, and whether contractual engagements can be reinterpreted by applying a four-fold test in determining an employer-employee relationship.

Whether a retired employee like Dr. Annang can validly file for the accreditation of service after retirement, in light of Section 100, Rule 21 of CSC Resolution No. 110-1502, which explicitly restricts such requests for those who have already retired.

Whether the Court of Appeals erred in applying the four-fold test—commonly used in private employment settings—to determine the existence of an employer-employee relationship in a government setting governed by civil service laws and special rules.
Whether the intrinsic terms of the contract, which clearly state that no employer-employee relationship exists and that service rendered cannot be credited as government service, should prevail over an analysis based solely on the four-fold test.

Whether the CSC rules and memorandum circular, which preclude the accreditation of service for work rendered under contracts of service, should take precedence over the factual findings regarding the nature of Dr. Annang’s work at CSU.

Whether the issue of Dr. Annang’s entitlement to retirement benefits under RA 8291 falls within the jurisdiction of the CSC for adjudication.