G.R. No. 213696 - Quantum Foods, Inc. vs. Esloyo

On October 1, 2012, Makati City Mayor Jejomar Erwin S. Binay, Jr. appointed Gerardo Kangleon San Gabriel as City Government Department Head II (General Services Officer, SG-26) at the Makati City General Services Department.
On February 25, 2013, the CSC-NCR issued a Letter invalidating San Gabriel’s appointment on two grounds:

He was a resident of Quezon City at the time of his appointment, not Makati City, as required.
He failed to meet the minimum educational requirements under Republic Act (RA) No. 7160, which mandate that a City General Services Officer must hold a college degree in public administration, business administration and management, or a closely related field, and be a first grade civil service eligible or its equivalent.

On May 30, 2014, Makati City Personnel Officer Vissia Marie Aldon filed a motion for reconsideration with the CSC-NCR.
The CSC-NCR treated the motion as an appeal but later dismissed it on January 13, 2015, holding that Aldon lacked legal personality since the real parties in interest are strictly the appointing authority (Mayor Binay) and the appointee (San Gabriel).
Key legal precedents, notably Abella vs. CSC, were cited to establish that only the appointing authority and the appointee have the requisite standing to contest a CSC decision on appointment matters.

Dissatisfied with the dismissal, Mayor Binay sought reconsideration by asserting that Aldon was acting on his behalf with proper authorization.
In his supplementary submission:

Mayor Binay presented evidence, including an Indorsement dated February 10, 2015, which claimed that Aldon acted on his behalf in challenging the CSC’s invalidation.
He argued that San Gabriel met the residency requirement, asserting that he resided in Makati City (at A-Venue Residences Tower 1), while the Quezon City townhouse belonged to San Gabriel’s sister.
He also contended that San Gabriel’s academic training and extensive experience in various government agencies qualified him for the position.

On November 29, 2016, the CA granted the petition for review (CA-G.R. SP No. 140570), reversing the CSC’s previous findings.
The CA held that Aldon, as the City Personnel Officer, had acted on behalf of Mayor Binay and was therefore empowered to file the motion for reconsideration.
The CA’s decision essentially affirmed San Gabriel’s appointment as compliant with the required qualifications in terms of residency and education.

The CSC petitioned the Supreme Court for review on certiorari, challenging both the CA decision and the process through which the motion for reconsideration was allegedly improperly filed by an ineligible party.
The Supreme Court evaluated the issues concerning:

Legal personality and the proper standing to file an appeal to contest the disapproval of an appointment.
The actual facts of San Gabriel’s qualifications, particularly his residency as stated in his Personal Data Sheet (PDS), which indicated he was a resident of Quezon City at the time of appointment.

The Court emphasized that the PDS is made under oath and constitutes a public document representing the applicant’s qualifications.

Whether Vissia Marie Aldon, as City Personnel Officer, had the legal personality to file a motion for reconsideration challenging the disapproval of San Gabriel’s appointment.
Whether the authorization presented by Mayor Binay retrospectively vests Aldon with the capacity to act as the appointing authority’s agent in this matter.

Whether the appointment of Gerardo Kangleon San Gabriel as City Government Department Head II is valid given the allegations that:

He did not satisfy the residency requirement (being a resident of Quezon City at the time of appointment rather than Makati City).
He failed to meet the educational qualification requirements prescribed under RA 7160.

Whether the evidence, including discrepancies in his PDS and supporting documentary proof (such as bills and certificates), is sufficient to conclude that San Gabriel lacked the necessary qualifications.

Whether the CSC properly exercised its personnel regulatory function by invalidating the appointment based on the non-compliance with the minimum qualification standards.
Whether the appellate procedures in place (as provided under CSC rules and relevant memoranda) allow for both the appointing authority and the appointee to challenge such disapprovals.