G.R. No. 193945 - Remington Industrial Sales Corp. vs. Maricalum Mining Corp.

On February 1, 2008, then Pasig City Mayor Roberto C. Eusebio appointed retired diplomat Rosalina V. Tirona as President of Pamantasan ng Lungsod ng Pasig (PLP) for a four-year term ending January 31, 2012.
The Civil Service Commission (CSC) approved Tirona’s appointment.
Upon re-election on June 7, 2010, Eusebio issued a memorandum requesting all Pasig City office chiefs, including Tirona, to tender courtesy resignations. Tirona refused, explaining her reasons in writing.
On July 19, 2010, Eusebio terminated Tirona’s appointment citing her reaching the compulsory retirement age of 70, declaring the PLP President position vacant.

Tirona challenged her termination before the CSC.
On September 23, 2010, the CSC ruled that Tirona was illegally dismissed and ordered her reinstatement as PLP President.
Eusebio and the PLP Board of Regents filed motions for reconsideration, which the CSC denied on December 13, 2010.
Both parties appealed to the Court of Appeals, which did not issue any injunctive relief restraining Tirona’s reinstatement.

Despite CSC’s directive, Eusebio did not reinstate Tirona.
On June 21, 2011, the CSC motu proprio charged Eusebio with indirect contempt.
Eusebio argued his non-compliance was without bad faith, claiming his appeal stayed the CSC order, and that Tirona never filed a motion to implement reinstatement.

On November 26, 2012, the CSC found Eusebio guilty of indirect contempt and imposed a fine of P416,000.00 computed at P1,000 per day from December 13, 2010, to February 1, 2012 (end of Tirona’s term).
The CSC ordered the Pasig City government to deduct the fine from Eusebio’s salary and remit it.
CSC relied on Section 82 of the Uniform Rules on Administrative Cases in the Civil Service (URACCS) which states CSC final rulings are immediately executory unless enjoined or restrained by courts.
The fine imposed was based on CSC Memorandum Circular No. 42, s. 1990 as amended by CSC Resolution No. 071245 (CSC Revised Rules on Contempt), prescribing a P1,000.00 per day fine for indirect contempt.

Eusebio filed a petition for review before the Court of Appeals (CA-G.R. SP No. 129526) contesting the indirect contempt ruling and fine.
The Court of Appeals affirmed the finding of guilt but reduced the fine from P416,000.00 to P30,000.00, stating the CSC exceeded its authority by imposing a daily fine not specifically fixed by law and that the fine imposed was unreasonable and confiscatory.
Both parties filed motions for reconsideration, which were denied.

The Civil Service Commission filed a petition before the Supreme Court seeking to reinstate the full P416,000.00 fine.
The Office of the Solicitor General (OSG) argued the CSC had constitutional and legal authority to promulgate its own rules and impose the penalty deemed necessary to enforce its rulings.
Eusebio maintained his non-compliance was not in bad faith and supported the CA’s decision reducing the fine.

Whether the Court of Appeals erred in reducing the fine imposed by the CSC on Roberto C. Eusebio for indirect contempt;
Whether the CSC had the authority to impose a P1,000 per day fine under its Revised Rules on Contempt despite no specific statute fixing that amount for contempt penalties.