G.R. No. 176162 - Civil Service Commission vs. Court of Appeals

Respondents Dante G. Guevarra and Augustus F. Cezar were, respectively, the Officer-in-Charge/President and Vice President for Administration of the Polytechnic University of the Philippines (PUP) in 2005.
Petitioner Honesto L. Cueva was then the Chief Legal Counsel of PUP.

On September 27, 2005, Cueva filed an administrative case against Guevarra and Cezar before the Civil Service Commission (CSC), charging:

Gross dishonesty
Grave misconduct
Falsification of official documents
Conduct prejudicial to the best interest of the service
Being notoriously undesirable
Violation of Section 4 of Republic Act (R.A.) No. 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees).

The specific allegation of falsification concerned the Application for Bond of Accountable Officials and Employees of the Republic of the Philippines (General Form No. 58-A) submitted by Guevarra, in which he responded negatively to the question of any existing criminal or administrative records, despite the undisputed fact of 17 pending cases filed against both respondents before the Sandiganbayan for violations of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act).
Cezar endorsed and recommended the approval of the bond application fully aware of the pending cases.

Respondents claimed that their negative answer meant no final conviction existed yet, as the cases were still pending.
The CSC conducted preliminary investigation and found prima facie evidence; on March 24, 2006, it issued Resolution No. 060521 charging Guevarra with dishonesty and Cezar with conduct prejudicial to the service.
Respondents filed Motions for Reconsideration and to Declare Absence of Prima Facie Case; Cueva filed motions for preventive suspension and inclusion of additional charges.
The CSC denied respondents’ motions and partially granted Cueva’s motions by imposing 90-day preventive suspension on Guevarra.

Respondents filed petitions for certiorari and prohibition before the Court of Appeals (CA), questioning the jurisdiction of the CSC over the administrative complaint.
On December 29, 2006, the CA ruled in favor of respondents, nullifying CSC resolutions on jurisdictional grounds. The CA held that:

Under Section 47, Chapter 7, Subtitle A, Title I, Book V of Executive Order No. 292 (Administrative Code of 1987), the Board of Regents of PUP had jurisdiction to investigate and decide disciplinary matters involving its officials and employees.
Cueva, though a government employee, was under the PUP Board’s jurisdiction; therefore, he should have first exhausted administrative remedies before the Board.
The CSC acted without jurisdiction and erred in taking cognizance of the complaint.

Whether the CSC has original concurrent jurisdiction over administrative cases against officials and employees of chartered state universities filed directly with it, irrespective of the identity of the complainant.

Does the Civil Service Commission have original concurrent jurisdiction with the Board of Regents of a chartered state university over administrative disciplinary cases filed directly with the CSC against its officials and employees?

Is the distinction between complaints filed by private citizens and those filed by government employees relevant to the CSC’s jurisdiction?

Does Republic Act No. 8292 (Higher Education Modernization Act of 1997) grant exclusive jurisdiction to the Board of Regents over administrative cases involving university officials and employees, thereby limiting CSC jurisdiction?