G.R. No. 268355 - People vs. Domingo Banguilan y Gulan

Peter G. Cutao (Cutao) began his career in the civil service as a Police Officer 1 (PO1) in the Philippine National Police (PNP).
He was promoted successively to PO3, Senior Police Officer 1 (SPO1), and Senior Police Officer 2 (SPO2), with all promotions approved by the Civil Service Commission (CSC).
For his promotion to SPO2, Cutao submitted a Personal Data Sheet indicating that he obtained a bachelor’s degree in criminology from the Agusan Institute of Technology (AIT) in Butuan City in 1997. He also submitted a transcript of records (TOR) from AIT and a Commission on Higher Education (CHED) Certification, Authorization and Verification (CAV) stating that the Bachelor of Science in Criminology course in AIT was duly authorized.

The CSC Regional Office (CSCRO) requested CHED Caraga Administrative Region to verify the authenticity of Cutao's educational documents.
CHED responded that the submitted TOR and CAV were “not authentic.”
CHED found that the signatures on the CAV were not genuine and the Special Order referenced in the transcript did not reflect Cutao’s name but another person’s.
Based on CHED’s verification, the CSCRO concluded that Cutao lacked the educational qualifications required for his promotional positions.

CSCRO issued a decision recalling Cutao’s promotional appointments to PO3, SPO1, and SPO2 due to failure to meet educational qualifications.
The CSCRO informed the PNP Regional Office No. XIII to revert Cutao to his original rank before promotions, adjusting compensation accordingly.
Cutao appealed the recall to the CSC Proper, which upheld the recall and invalidated his promotions.
Cutao filed a Motion for Reconsideration with the CSC Proper, submitting letters from AIT officials attesting to his enrollment and compliance with graduation requirements, but the CSC denied the motion citing lack of new evidence.

Cutao elevated the case to the Court of Appeals (CA), arguing deprivation of due process when the CSCRO recalled his appointments without prior notice and hearing.
The CA reversed the decisions of the CSC and CSCRO, ruling that:

The CHED verification slip was not substantial evidence to recall appointments.
Cutao had acquired a legal right to his offices after seven years of service and relied in good faith on his educational documents.
Due process requires notice and hearing before recalling appointments.

The CSC filed a Petition for Review on Certiorari to the Supreme Court contesting the CA’s rulings.

Whether the Civil Service Commission (CSC) may recall a previously approved appointment without prior notice and hearing.