Facts:

The case involves Gabriel Moralde as the respondent against the Civil Service Commission and the Province of Misamis Oriental, who are the petitioners. The events leading to the case began when Moralde was employed as a Dental Aide in the Provincial Health Office of Misamis Oriental, where he was assigned to the municipalities of Villanueva and Claveria. He had a history of misconduct, including falsifying public documents and frequent absences without leave. In 1998, he was formally charged with falsifying his Daily Time Records for March and April of that year. Following an investigation, the Provincial Attorney recommended his dismissal due to repeated infractions.

On November 8, 1998, while the administrative case against him was still pending, Moralde filed an application for retirement with the Government Service Insurance System (GSIS). The next day, the then Provincial Governor issued a memorandum finding Moralde guilty of falsification and dismissing him from servi...

Facts:

Employment and Misconduct: Gabriel Moralde was employed as a Dental Aide in the Provincial Health Office of Misamis Oriental. He was assigned to the municipalities of Villanueva and Claveria. The Province alleged that Moralde had a history of falsifying public documents by forging his supervisor's signature on his Daily Time Records (DTRs) and had a record of frequent absences without leave and habitual tardiness.

Administrative Case: Moralde was formally charged with falsifying his DTRs for March and April 1998. An investigation revealed that he did not report for work during those months. After the investigation, Atty. Danilo P. Rubio recommended Moralde’s dismissal from service due to his repeated infractions.

Retirement Application: While the administrative case was pending, Moralde applied for retirement under Republic Act No. 8291 (the Revised Government Service Insurance Act of 1977) on November 8, 1998. The next day, November 9, 1998, the Provincial Governor, Antonio P. Calingin, issued a memorandum finding Moralde guilty of falsification and dismissing him from service.

Approval of Retirement: On March 20, 2003, the Government Service Insurance System (GSIS) approved Moralde’s retirement application, with the retirement effective on November 8, 1998. Moralde did not inform the Province or the Civil Service Commission (CSC) about his retirement approval.

Appeal and Reinstatement Order: Moralde appealed his dismissal to the CSC, which initially set aside the dismissal order in 2005 and directed his reinstatement in 2006. However, during the processing of his reinstatement, the Province discovered that Moralde had retired in 1998. The Province filed a motion for new trial, arguing that Moralde’s reinstatement was moot due to his retirement.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Voluntary Severance of Employment: Moralde’s application for retirement benefits constituted a voluntary termination of his employment. By applying for retirement, he affirmatively acted to end his service with the government. Public officers who voluntarily separate from service cannot later demand reinstatement, especially when the separation was made to avoid administrative liability.

2. Immutability of Judgments: While judgments are generally immutable, exceptions apply when supervening events render execution impractical or unjust. In this case, Moralde’s retirement constituted such a supervening event, making his reinstatement untenable.

3. No Illegal Dismissal: Moralde was not illegally dismissed because he had already retired before the dismissal order was issued. His retirement nullified any claim for reinstatement and backwages.

4. Estoppel: Moralde was estopped from seeking reinstatement because he concealed his retirement from the Province and the CSC. His actions demonstrated an intent to terminate his employment voluntarily, and he cannot now claim the benefits of reinstatement.

Conclusion:

The Supreme Court emphasized that public service is a public trust, and employees must act with integrity. Moralde’s duplicitous actions in applying for retirement while appealing his dismissal were inconsistent with the principles of public service. The Court’s decision reaffirms that employees who voluntarily terminate their employment cannot later demand reinstatement.