Title
Civil Service Commission vs. Court of Appeals
Case
G.R. No. 176162
Decision Date
Oct 9, 2012
The Court affirms the Civil Service Commission's authority to handle administrative cases against state university officials, reinstating misconduct charges against them.
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Case Digest (G.R. No. 176162)

Facts:

  • The case involves consolidated petitions for review under Rule 45 of the Revised Rules of Civil Procedure: G.R. No. 176162 and G.R. No. 178845.
  • The petitioner is the Civil Service Commission (CSC), while the respondents are Dr. Dante G. Guevarra and Atty. Augustus F. Cezar.
  • An administrative complaint was filed on September 27, 2005, by Honesto L. Cueva, Chief Legal Counsel of the Polytechnic University of the Philippines (PUP), against Guevarra and Cezar.
  • The complaint alleged gross dishonesty, grave misconduct, falsification of official documents, conduct prejudicial to the service, and violations of Section 4 of Republic Act (R.A.) No. 6713.
  • Guevarra was accused of falsifying a public document by denying pending criminal and administrative cases against him in his Application for Bond of Accountable Officials and Employees.
  • At the time of the application, both respondents had 17 pending cases for violations of Section 3(e) of R.A. No. 3019.
  • Cezar endorsed Guevarra's application, knowing about the pending cases.
  • The respondents argued that their understanding of "criminal or administrative records" referred only to final convictions.
  • On March 24, 2006, the CSC formally charged Guevarra with dishonesty and Cezar with conduct prejudicial to the service.
  • Both respondents filed motions for reconsideration, which were denied by the CSC.
  • Guevarra was placed under preventive suspension for 90 days, leading to a petition for certiorari and prohibition before the Court of Appeals (CA).
  • On December 29, 2006, the CA ruled in favor of the respondents, nullifying the CSC's resolutions on jurisdictional grounds.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of the petitioners, affirming that the CSC has concurrent original jurisdiction over administrative cases filed directly with it, regardless of the complainant's status.
  • ...(Unlock)

Ratio:

  • The ruling was based on the interpretation of Section 47, Chapter 7, Subtitle A, Title I, Book V of Executive Order No. 292 (the Administrative Code).
  • The Court clarified that the CSC, as the central personnel agency, has the authority to hear and decide administrative cases filed directly with it, including those initiated by government employees.
  • The law's language does not limi...continue reading

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