G.R. No. 160568 - Civil Service Commission vs. Pobre

Petitioner: The Civil Service Commission (CSC)
Respondent: Hermogenes P. Pobre, a former government official with three retirements

First retirement – Commissioner of the Commission on Audit (COA) on March 31, 1986
Second retirement – Chairman of the Board of Accountancy on October 31, 1990
Third retirement – Associate Commissioner (and later Chairman) of the Professional Regulation Commission (PRC), retiring as chairman on February 17, 2001

In his first two retirements, Pobre received terminal leave pay of P310,522.60 and P55,000, respectively
In his third retirement, he claimed terminal leave benefits to be computed from his original government service appointment in 1958, based on Section 13 of Commonwealth Act No. 186

The controversy arose when respondent Pobre sought terminal leave benefits computed over the entire period of service instead of limiting it to his latest appointment as PRC chairman
The successor PRC chairperson, Antonieta Fortuna-Ibe, sought opinions from the CSC and the COA regarding the validity of the claim
On October 29, 2001, the CSC promulgated Resolution No. 01-1739, ruling that Pobre was entitled only to terminal leave benefits computed from his assumption of office as PRC chairman
After Pobre filed for reconsideration, the CSC on February 19, 2002, issued Resolution No. 02-0236

This resolution maintained the denial of the full claim but modified the computation to include his period as PRC associate commissioner
It concluded that his terminal leave benefits should only be computed from his appointment as PRC commissioner until his retirement as PRC chairman

Dissatisfied with the CSC resolutions, respondent Pobre elevated the case to the Court of Appeals
The Court of Appeals, in a decision dated March 31, 2003, annulled the CSC resolutions on the ground of lack of jurisdiction

It held that the COA, not the CSC, had the proper jurisdiction to adjudicate the claim regarding terminal leave benefits
The Court of Appeals ordered the parties to await the outcome of the PRC’s query to the COA regarding this matter

Petitioner CSC filed a motion for reconsideration which was denied on September 24, 2003, leading to the present petition for review

Invoked its authority under the 1987 Administrative Code and PD 807 (Civil Service Decree of the Philippines)
Powers include administering retirement programs and enforcing rules for personnel administration

Constitutionally mandated to examine, audit, and settle government accounts and expenditures
Statutorily empowered under Article IX-D of the 1987 Constitution and Section 26 of PD 1445 (Government Auditing Code of the Philippines)

The fundamental question revolved around the exclusive jurisdiction to determine the legality and computation of terminal leave benefits when government funds are involved

Whether the CSC had jurisdiction to pass upon the validity of respondent Pobre’s claim for terminal leave benefits computed from his original government service start date in 1958 up to his retirement as PRC chairman
Whether the claim could be adjudicated by the CSC given that Pobre had already received terminal leave benefits in his previous retirements and that the claim involved government funds

Whether, upon the invocation of Section 13 of Commonwealth Act No. 186, the computation of terminal leave benefits should include all accrued leave credits across different agencies
Whether the COA, rather than the CSC, was the proper tribunal to assess the legality of the computation of such benefits involving public funds