G.R. No. 204766 - Department of Health vs. Aquintey

A controversy arose regarding the rightful designation of the Officer-in-Charge (OIC) of the Ilocos Training and Regional Medical Center (ITRMC).
On February 4, 2002, Dr. Gilbert De Leon was designated OIC for a one‑year term by then DOH Secretary Dr. Manuel A. Dayrit, but he remained in office beyond the prescribed period.
On June 6, 2003, Secretary Dayrit relieved Dr. De Leon and designated Dr. Eduardo C. Janairo as his replacement, which prompted dispute as Dr. De Leon later challenged the act leading to consequential legal and procedural issues.

Acting under his assumed role as the duly designated OIC, Dr. Janairo issued several directives:

Office Order No. 1414 (November 14, 2003) directed respondents Aquintey and Mendoza to inventory hospital properties and simultaneously relieved them temporarily of their regular duties.
Memorandums Nos. 55 (November 18, 2003) and 60 (November 20, 2003) ordered all three respondents (Aquintey, Mendoza, and Villanueva) to cease performing their official duties and to refrain from signing crucial documents.
Subsequent issuances (a Letter dated November 20, Memorandum No. 34, Memorandum No. 66, Office Memorandum No. 068-A, and Memorandum No. 71) further directed them to comply with operational protocols and accountabilities.

Respondents failed to adhere to these orders, which underpinned the subsequent administrative case filed against them.

On February 24, 2004, an administrative complaint was filed by the Center for Health Development I (represented by Dr. Janairo in his capacity as OIC) before the Department of Health (DOH), charging the respondents with gross insubordination, grave misconduct, gross neglect of duty, and conduct prejudicial to the best interest of the service.
Prior controversies including a dispute between Dr. Janairo and Dr. De Leon, involvement of the Regional Trial Court (RTC) through a Temporary Restraining Order (TRO) and a writ of preliminary injunction, and subsequent orders preserving the status quo by the RTC and Court of Appeals (CA), set the stage for the administrative proceedings.
Secretary Dayrit’s issuance of Department Order No. 231-D affirmed Dr. Janairo’s role as OIC notwithstanding the continuity of the dispute due to Dr. De Leon’s refusal to vacate the office.

On July 12, 2007, then DOH Secretary Francisco T. Duque III rendered a decision in Administrative Case No. 51‑04 finding the respondents guilty of multiple administrative offenses, including gross insubordination, and imposed dismissal from service along with its accessory penalties.
The respondents appealed the decision to the Civil Service Commission (CSC), which, on October 6, 2008, modified the sanction: It found them guilty only of gross insubordination and imposed a penalty of nine (9) months suspension.
A subsequent motion for reconsideration by the respondents was denied by the CSC on March 31, 2009.

Unsatisfied with the CSC resolution, the respondents filed a petition for review with the Court of Appeals (CA).
On March 20, 2012, the CA reversed and set aside the CSC resolutions, ordering instead that the respondents be paid their salaries during the nine‑month suspension.
The CA based its decision on the premise that the respondents’ disobedience stemmed from their good‑faith belief that Dr. De Leon was the rightful OIC.

The Department of Health, represented by Secretary Enrique T. Ona, later filed a petition for review on certiorari challenging the CA’s decision.
The Supreme Court, noting the continuing controversy over the issuance of lawful orders by Dr. Janairo and the respondents’ failure to comply despite clear directives, found merit in the petition.
The Court emphasized that the status quo was established by Dr. Janairo’s assumption of office, a fact uncontested in the CA resolution.

Whether the employees (respondents Aquintey, Mendoza, and Villanueva) committed gross insubordination by refusing to comply with the lawful and reasonable orders of Dr. Janairo in his capacity as OIC.

Does the respondents’ failure to follow direct orders—despite the controversial dispute over the rightful OIC—constitute gross insubordination?
Is their claimed good‑faith belief that Dr. De Leon should occupy the position an adequate excuse for their noncompliance with established orders?
How should the status quo, as maintained by the CA’s earlier resolution and the DOH Secretary’s order, affect the determination of administrative liability?