G.R. No. 163586 - Castro vs. Deloria

On December 14, 1994, then-Mayor Jose Salcedo appointed Jocelyn Gentallan as the local civil registrar of the Municipality of Jasaan, Misamis Oriental.
Commissioner Thelma Gaminde of the Civil Service Commission (CSC) confirmed that Gentallan’s work experience satisfied the minimum requirement of three years for the position.
When the Sangguniang Bayan of Jasaan did not act within fifteen days, the appointment was deemed approved, and on January 5, 1995, the CSC Regional Office No. 10 (CSCRO-10) approved her appointment on a permanent basis.

Rosalina Asis, a research aide in the Office of the Local Civil Registrar, filed a protest against Gentallan’s appointment.
The CSC dismissed the protest on August 31, 1995, via Resolution No. 95-5317, on the ground that the protestant was not the qualified next-in-rank.
Notwithstanding the dismissal, the CSC reviewed Gentallan’s qualifications and held that she did not meet the required three-year relevant experience.
Gentallan’s motion for reconsideration was denied in CSC Resolution No. 96-0582 dated January 25, 1996.

Gentallan filed a petition for review before the Court of Appeals, docketed as CA G.R. SP No. 40482.
On October 22, 1997, the Court of Appeals set aside the disputed CSC resolutions and declared that Gentallan was qualified for the position.
The decision became final and executory on November 15, 1997.
On September 2, 1998, Regional Director Jose T. Soria of CSCRO-10 informed Mayor Paurom of the appellate decision and instructed him to reinstate Gentallan.

Despite the Court of Appeals’ decision, Mayor Paurom of Jasaan did not immediately reinstate Gentallan.
Gentallan, through counsel, sought the intervention of CSCRO-10 for an order directing the municipality to reinstate her and pay her backwages.
Following ensuing legal pressures, an agreement was reached: on December 21, 1998, the mayor issued a memorandum directing her to assume office as local civil registrar and a subsequent notice adjusting her salary was issued.
Subsequently, Gentallan inquired about her entitlement to back salaries, representation and travel allowance (RATA), and bonuses.
On June 14, 1999, Regional Director Annabelle B. Rosell of CSCRO-10 issued an order granting these entitlements.

The provincial attorney concurred with Gentallan’s entitlement based on the finality of the Court of Appeals’ decision.
However, Mayor Paurom and the Sangguniang Bayan of Jasaan did not appropriate funds for her back salaries, eventually reallocating the appropriations meant for her compensation to other projects (i.e., the Active Night Assistance Center).
The CSC, initially supportive with CSCRO-10’s order, reversed its position in CSC Resolution No. 001264 dated May 24, 2000, stating that Gentallan was not illegally dismissed and thus was not entitled to the claimed benefits.
A subsequent motion for reconsideration of Gentallan’s claims was also denied by the CSC in Resolution No. 002305 dated October 11, 2000.

The Court of Appeals’ determination on the CSC’s lack of standing.
The implication that reinstatement automatically warrants the grant of back salaries and differential bonuses.

G.R. No. 154961 by the Municipality of Jasaan (represented by Mayor Paurom), arguing:

Central to both petitions was the question of whether Jocelyn Gentallan is entitled to back salaries, RATA, and bonuses, considering the interplay of CSC orders, administrative actions, and the subsequent appellate decision.
Gentallan further contended that her removal was irregular and tainted with malice, whereas the municipality maintained that her reversion to Assistant Registration Officer was a lawful consequence of following CSC orders.
The outcome of the appellate decision—which declared her qualified and ordered reinstatement with all monetary benefits—remained a cornerstone of her claim.

Whether the CSC has the legal standing to file an appeal or motion for reconsideration in a case reviewing its own resolution on the qualifications and reinstatement of a civil servant.
Whether a government agency may question its own administrative decision when it adversely affects its personnel management functions.

Whether the reinstatement of Gentallan to her position necessarily implies the award of back salaries, RATA, and differential bonuses.
Whether the alleged illegal dismissal, now reversed by the Court of Appeals, entitles her to monetary benefits covering the period from her dismissal to her effective reinstatement.

Whether the CSC resolutions and the subsequent administrative actions taken by the municipality operated to legally remove Gentallan from office.
Whether the municipality’s failure to implement the reinstatement order and the reallocation of appropriated funds prejudiced Gentallan’s statutory rights and privileges.

Whether Gentallan’s removal complied with the due process requirements dictated by law since a permanently appointed civil servant enjoys security of tenure.
Whether the subsequent actions in the chain of administrative decisions nullify the effects of an illegal dismissal.