G.R. No. 215932 - Civil Service Commission vs. Rebong

Respondent, Richard S. Rebong, served as an Intelligence Agent 1 (IA 1) initially in the then Economic Intelligence and Investigation Bureau (EIIB) of the Bureau of Customs (BOC) from October 1994 to January 2000, and later in the Customs Intelligence and Investigation Service (CIIS) of the BOC from March 2004 until May 2012.
During his service as IA 1, he was assigned duties that included intelligence gathering, surveillance, search and seizure operations, and preparation of mission reports, all pursuant to the enforcement of the Tariff and Customs Code of the Philippines (TCCP) and related laws.
Prior to his government service, respondent held various positions in the private sector, which, along with his academic credentials (bachelor’s degree in business administration, master’s and doctorate in public administration), were part of his overall profile.

In the EIIB, he led the Special Operations Group (SOG) at the Container Yard (CY), Container Freight Station (CFS), and Customs Bonded Warehouses (CBW) of the Port of Manila and the Manila International Container Port.
In the CIIS, he served as Team Leader for the sub-unit at the Philippine Economic Zone Authority (PEZA) covering provinces like Rizal, Cavite, Laguna, and Batangas, managing a team tasked with safeguarding shipments.

In addition, under Office Order No. 2-2007, he was designated as Field Officer for the X-Ray Inspection Project at the Manila International Container Port, responsible for operational control, supervision of x-ray inspectors, and coordination with various agencies.
A subsequent designation came under Customs Personnel Order No. B-7-2008, which reassigned him as Assistant Officer-in-Charge of the CIIS-PEZA Cavite/Laguna and its extensions.
These assignments, though executed while he still held the IA 1 rank, involved additional managerial and supervisory tasks that later became central to the dispute over his qualifications.

When the position of Intelligence Officer V became vacant, respondent applied for the post and was evaluated by the Personnel Selection Board (PSB).
Out of several candidates, he was shortlisted as one among the three finalists based on his credentials and was ultimately appointed by then Commissioner Razzano Rufino Biazon on May 10, 2012, with a permanent appointment confirmed on May 15, 2012 by promotion.
The appointment was forwarded to the Civil Service Commission Field Office-Department of Public Works and Highways (CSCFO-DPWH) for evaluation and attestation.

Respondent’s permanent appointment was disapproved on the ground that he did not meet the requisite experience and training qualifications.

The CSC-NCR, in its Decision dated August 30, 2012, acknowledged that while respondent met the educational and eligibility requirements, his work as IA 1 was not credited for management and supervisory experience.
Only his brief stint as an Account Manager was recognized as satisfying the experience requirement.

Subsequent administrative remedies included a motion for reconsideration by respondent, which was treated as a petition for review by the CSC and resolved through a Decision on July 26, 2013, and later resolutions dated November 11, 2013, and February 25, 2014, all denying the credit for his additional assigned duties.

Respondent elevated the issue by filing a petition for review before the CA.
In its August 29, 2014 Decision, the CA reversed and set aside the earlier CSC rulings by holding:

The Qualification Standards for the IO V position required experience in positions involving management and supervision but did not mandate that the prior employment be functionally identical to the IO V duties.
Respondent’s assignments as Team Leader and Field Officer, performed as additional tasks under his IA 1 position, did satisfy the management and supervisory experience requirement.
The trainings, including a 96-hour course for the X-Ray Inspection Project, were credited as meeting the management and supervisory training requirement.

The CA ruling thereby upheld respondent’s appointment as IO V and reversed the disapproving decisions of the CSC.

Petitioner (represented by the CSC) filed a Petition for Review on Certiorari before the Supreme Court challenging the CA ruling.
The assignment of errors included three major contentions:

That the CA erred in finding respondent satisfied the four-year managerial/supervisory experience requirement.
That the CA erred in crediting his designation as Team Leader and Field Officer as experience in management and supervision.
That the CA erred by ruling that respondent’s appointment did not violate the three-salary-grade rule.

Respondent countered that his additional responsibilities and the evidence in sworn statements adequately substantiated his compliance with the Qualification Standards, and that his experience should be credited despite the initial classification as IA 1.

Whether respondent’s assigned roles and additional duties (as Team Leader and Field Officer) while holding the position of IA 1 qualify as experience involving management and supervision for the IO V position.
Whether the designation of a first level position holder (IA 1) to perform tasks of a second level position constitutes an impermissible designation under CSC rules and if such designation should affect the crediting of experience.
Whether the disapproval of respondent’s permanent appointment by the CSC—based on the alleged non-compliance with the experience and training requirements and the application of the three-salary-grade rule—is proper and legally supportable.
Whether the CA’s interpretation of the Qualification Standards (which enumerated educational, experience, training, and eligibility requirements, without a strict functional-relatedness criterion) is consistent with the statutory and administrative regulations.
Whether the CSC’s restrictions on designation and the alleged violation of the three-salary-grade rule can override the discretion of the appointing authority, especially in very meritorious cases.