Case Digest (G.R. No. 115863)
Facts:
Aida D. Eugenio v. Civil Service Commission, G.R. No. 115863, March 31, 1995, the Supreme Court En Banc, Puno, J., writing for the Court. Petitioner Aida D. Eugenio was then Deputy Director of the Philippine Nuclear Research Institute; respondents were the Civil Service Commission (CSC) and Commissioners Teofisto T. Guingona, Jr. and Salvador Enriquez, Jr.
Petitioner applied for Career Executive Service (CES) eligibility and a CESO rank. She received CES eligibility on August 2, 1993, and on September 15, 1993 the Career Executive Service Board (CESB) recommended her to the President for a CESO rank. On October 1, 1993 the CSC promulgated Resolution No. 93-4359, which declared that the Career Executive Service Board "shall now be known as the Office for Career Executive Service of the Civil Service Commission" and that the CESB's personnel, budget, properties and equipment would form part of that Office.
Because of Resolution No. 93-4359, the Office of the President (via Chief Presidential Legal Counsel Antonio T. Carpio in a June 7, 1994 letter) refrained from filling CESO appointments pending legal clarification. Petitioner then filed a petition for certiorari and prohibition to annul Resolution No. 93-4359, arguing that the CSC usurped Congress' power by abolishing an office created by law and by authorizing transfer of public funds. The Solicitor General agreed with petitioner; the CSC defended the resolution, arguing (inter alia) that the petition stated no cause of action, that the CESB's recommendation was valid, that the President was estopped from questioning the recommendation, and that the integration was authorized by Section 12(1), Title I, Subtitle A, Book V of the ...(Subscriber-Only)
Issues:
- Does the petition state a cause of action challenging CSC Resolution No. 93-4359?
- Did the Civil Service Commission have authority to abolish or integrate the Career Executive Service Board into its organization by CSC Resoluti...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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