Case Digest (G.R. No. 197792)
Facts:
Civil Service Commission v. Madlawi B. Magoyag, G.R. No. 197792, December 09, 2015, Supreme Court Third Division, Peralta, J., writing for the Court.Respondent Madlawi B. Magoyag filed a petition before the Regional Trial Court (RTC) of Lanao del Sur (Special Proceeding No. 1716‑07) to correct his date of birth from July 22, 1947 to July 22, 1954. On November 20, 2007 the RTC granted the petition, ordering the Government Service Insurance System and the Bureau of Customs (at Cagayan de Oro) to correct their records to reflect the corrected date; the RTC decision was amended on June 2, 2008 to additionally direct the Local Civil Registrar of Tamparan and the Civil Service Commission (CSC) to immediately effect the correction in their records.
On February 6, 2008 respondent, then Deputy Collector of the Bureau of Customs in Cagayan de Oro, submitted a request to CSC Regional Office No. X (later endorsed to CSC‑NCR and to CSC central) to correct his employment records to reflect July 22, 1954. He supported the request with his NSO certificate of live birth, the RTC decision, a delayed registration certificate from the Local Civil Registrar, a sworn affidavit, joint affidavits of witnesses, and school records (diploma and transcript).
The CSC denied the correction by Resolution No. 09‑0987 dated July 7, 2009 on the ground that the RTC decision was not yet final and executory. Respondent filed a motion for reconsideration attaching a Certificate of Finality issued by the RTC (dated June 17, 2008), but CSC again denied reconsideration in Resolution No. 10‑0491 dated March 16, 2010. Respondent then filed a petition for review under Rule 43 of the Rules of Court with the Court of Appeals (CA) arguing that CSC’s resolutions were appealable as quasi‑judicial acts and that CSC was bound to comply with the RTC’s final judgment.
The CA granted respondent’s petition and directed the CSC to comply ...(Subscriber-Only)
Issues:
- Are the CSC Resolutions Nos. 09‑0987 (July 7, 2009) and 10‑0491 (March 16, 2010) reviewable by the Court of Appeals under Rule 43 of the Rules of Court?
- If reviewable, did the Court of Appeals err in directing the CSC to comply with the RTC decision correcting respon...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)