G.R. No. L-246 - Valdez vs. Lucero

Fatima A. Macud, a public school teacher, was appointed as Teacher I by the Department of Education in Marawi City.
As a requirement for her appointment, she submitted her Personal Data Sheet (PDS) to the CSC Regional Office XII, wherein she claimed to have passed the October 23, 1994 Professional Board Examination for Teachers (PBET) in Iligan City with a rating of 76.26%.

The Application Form (AF) and the Picture-Seat Plan (PSP) from the PBET indicated her birth date as December 15, 1958.
Her PDS, however, listed her birth date as December 15, 1965.

Photographs attached to the AF and PSP were found to be notably different from the one attached to the PDS.
Macud explained that these differences were due to the pictures being taken in different years (1993 for the AF/PSP and 2002 for the PDS).

The signature on her PDS differed from that on the AF and PSP.
Macud attributed the difference to changes following her marital status, which led to the adoption of her husband’s surname.

On November 27, 2002, CSC Regional Office XII formally charged Macud with Dishonesty, Grave Misconduct, and Conduct Prejudicial to the Best Interest of the Service.
The charge was predicated on the evidence showing inconsistencies in her submitted documents, suggesting that she may have allowed another person to take the PBET on her behalf.
A formal investigation was conducted on August 19, 2003; despite her failure to attend, the investigation proceeded with documentary evidence, including copies of her PDS (from 2002 and 1987), the AF, the PSP, and her appointment papers.

On January 27, 2004, CSCRO XII rendered a decision finding Macud guilty and recommended her dismissal from service along with accessory penalties such as perpetual disqualification from holding public office and the revocation of her civil service eligibility.
Macud filed a motion for reconsideration, which was denied on March 23, 2004.
On appeal to the CSC Central Office, Macud raised issues of jurisdiction and the sufficiency of evidence.
Resolution No. 050780 by the CSC on June 15, 2005, dismissed her appeal and affirmed the earlier decisions.

The CA originally set aside the decisions of the CSC on the sole ground of lack of jurisdiction, holding that administrative cases against public school teachers fall under the exclusive jurisdiction of an Investigating Committee created pursuant to Section 9 of Republic Act No. 4670 (Magna Carta for Public School Teachers).
Macud also argued there was insufficient evidence to conclusively prove her guilt, citing the lack of witness and expert evidence concerning the photographic and signature discrepancies as well as the ambiguous establishment of her true birth date.

The petition for review on certiorari filed by the CSC sought to set aside the CA’s decision and reinstate its determinations based on jurisdiction under Presidential Decree No. 807 and Executive Order No. 292.
The CSC contended that, as the central personnel agency of the government mandated by the 1987 Constitution, it inherently possesses the authority to enforce the merit system and discipline its employees, including public school teachers.

Whether the CSC, as established under the Civil Service Law (P.D. No. 807) and the 1987 Constitution, has inherent jurisdiction to hear and decide administrative cases against public school teachers, despite the existence of RA 4670 which creates an Investigating Committee specifically for public school teachers.
Whether special laws like RA 4670 divest the CSC of its authority over disciplinary cases involving allegations of dishonesty and grave misconduct.

Whether the discrepancies in the personal documents (date of birth, photographs, and signatures) were sufficient to establish a prima facie case of fraud and misconduct against Macud.
Whether Macud was afforded the requisite due process in the administrative proceedings before the CSC, including proper notice and the opportunity to defend herself.

Whether Macud, by participating in and not timely objecting to the proceedings before the CSC, is estopped from later challenging the CSC’s jurisdiction on the grounds of lack of proper authority.