G.R. No. L-43203 - Cristobal vs. Melchor

Jose C. Cristobal was appointed as private secretary in the President’s Private Office, Malacañan, Manila, on July 1, 1961, receiving an annual salary of P4,188.00. He was a third grade civil service eligible with eight years of government service.
On or about the second week of January 1962, Executive Secretary Amelito R. Mutuc informed Cristobal by a letter dated January 1, 1962, that his services were terminated effective immediately. Similar letters were sent to other employees of the President’s Office.
The dismissed employees, including Cristobal, sought reconsideration via letters dated January 3, 1962, and January 26, 1962, which was denied by Mutuc on February 27, 1962, acting by authority of the President.

Five dismissed employees (excluding Cristobal) filed a civil action (Raul R. Ingles, et al. vs. Amelito R. Mutuc, et al., Civil Case No. 49965) on March 24, 1962, seeking reinstatement and back salaries from January 1, 1962. The lawsuit was initially dismissed but reversed by the Supreme Court on November 29, 1968, declaring their removal illegal and ordering their reinstatement with salaries.
In May 1962, some dismissed employees involved in the Ingles case were recalled to their positions without prejudice to their pending court case. Others, like Cristobal, were not reinstated but were subject to efforts by Secretary Mutuc to find suitable placements outside Malacañan.

Cristobal continuously requested reinstatement from Executive Secretaries succeeding Mutuc, who assured him assistance at an “opportune time.”
After the Supreme Court decision in the Ingles case, Cristobal wrote a letter on January 19, 1969, requesting reinstatement and back pay starting from January 1, 1962, referencing the Ingles ruling.
Multiple subsequent letters from the Office of the President between 1969 and 1971 denied Cristobal’s request, the last letter dated May 19, 1971, declaring the matter “definitely closed.”
Cristobal filed a complaint on August 10, 1971, against Executive Secretary Alejandro Melchor and Cash Disbursing Officer Federico Arcala seeking:

An amended complaint added Leticia B. Nonato and her husband Simplicio Nonato as defendants, asserting that Leticia was appointed to Cristobal’s former position. The Nonatos were declared in default for failure to answer.
Trial ensued, with parties submitting documentary evidence, after which the defendants presented no evidence.

On May 18, 1972, the Court of First Instance dismissed Cristobal’s complaint, applying Section 16, Rule 66 of the Rules of Court, which requires quo warranto actions against public officers to be filed within one year of cause of ouster.
The court held that failure to file within one year constituted abandonment of the right to contest dismissal despite attempts to seek administrative remedies.

Whether Jose C. Cristobal lost his right to judicial relief for reinstatement and back pay by failing to file the complaint within one year from his dismissal, as required by Section 16, Rule 66 of the Rules of Court.

Whether the principle of laches or prescribed action applies, considering the dismissal was allegedly illegal and contrary to law.

Whether Cristobal’s non-participation in the Ingles case and the delay in filing his suit justified dismissal of his complaint.

What relief, if any, is Cristobal entitled to, given the circumstances surrounding his dismissal and efforts to secure reinstatement.