Case Digest (G.R. No. L-23721)
Facts:
- Petitioner-appellant R. Marino Corpus was the "Special Assistant to the Governor, In-Charge of the Export Department" at the Central Bank of the Philippines, a position declared highly technical by the President on January 24, 1957.
- On March 7, 1958, Corpus faced administrative charges from co-employees for dishonesty, incompetence, neglect of duty, abuse of authority, oppression, conduct unbecoming a public official, and violation of internal regulations.
- On March 18, 1958, the Monetary Board suspended Corpus and formed a three-man investigating committee.
- The committee, after detailed hearings, recommended Corpus's immediate reinstatement on May 5, 1959, finding no grounds for disciplinary action.
- Despite this, on July 20, 1959, the Monetary Board, citing loss of confidence by the Governor, deemed Corpus resigned as of his suspension date.
- Corpus's motion for reconsideration was denied, prompting him to file an action for certiorari, mandamus, quo warranto, and damages with preliminary injunction in the Court of First Instance of Manila.
- The court declared the Board's resolution null and void, ordered Corpus's reinstatement, and awarded him P5,000.00 in attorney's fees.
- Both parties appealed to the Court of Appeals, which then certified the appeals to the Supreme Court to avoid splitting them.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that loss of confidence is not a valid ground for the removal of highly technical employees in the Civil Service.
- The Supreme Court affirmed the award of P5,000.0...(Unlock)
Ratio:
- The Supreme Court found the Central Bank authorities' appeal untenable, highlighting that the loss of confidence claim was an afterthought when charges against Corpus were unproven.
- The Monetary Board failed to provide specific findings to support the loss of confidence, relying only on the Governor's statement.
- The Constitution mandates that no public officer or employee in the Civil Service shall be removed or suspended except for cause as provided by law, which includes highly technical positions.
- The court clarified that while the tenure for primarily confidential positions co...continue reading
Case Digest (G.R. No. L-23721)
Facts:
The case involves R. Marino Corpus as the petitioner and Miguel Cuaderno, among others, as respondents. The events leading to the case began on March 7, 1958, when R. Marino Corpus, who was serving as the "Special Assistant to the Governor, In-charge of the Export Department" of the Central Bank, faced administrative charges from several co-employees. The charges included dishonesty, incompetence, neglect of duty, abuse of authority, oppression, conduct unbecoming a public official, and violations of the internal regulations of the Central Bank. Following these allegations, on March 18, 1958, the Monetary Board suspended Corpus and established a three-member investigating committee to look into the matter. This committee, after extensive hearings and a thorough review of the evidence, concluded in its report dated May 5, 1959, that there was no basis for disciplinary action against Corpus and recommended his immediate reinstatement.
However, on July 20, 1959, the Monetary Board, after deliberating on the committee's report and considering the service record of Corpus, resolved that he was deemed to have resigned due to the loss of confidence expressed by the Governor. Corpus sought reconsideration of this resolution, which was denied, prompting him to file a case for certiorari, mandamus, quo warranto, and damages, along with a request for a preliminary injunction, in the Court of First Instance of Manila. The trial court ruled in favor of Corpus, declaring the Monetary Board's resolution null and...