Case Digest (G.R. No. 223623)
Facts:
In 2008, Roberto C. Eusebio appointed retired diplomat Rosalina V. Tirona as President of the Pamantasan ng Lungsod ng Pasig for a term ending January 31, 2012, and the Civil Service Commission approved the appointment. After Mayor Eusebio terminated Tirona by letter dated July 19, 2010, the CSC held on September 23, 2010 that Tirona was illegally dismissed and ordered her reinstatement, which Eusebio refused to implement; the CSC found him guilty of indirect contempt by Decision dated November 26, 2012 and imposed a fine of P1,000.00 per day totaling P416,000.00. The Court of Appeals on July 21, 2015 affirmed liability but reduced the fine to P30,000.00, and the CSC sought review in the Supreme Court, which issued its decision on January 29, 2020.
Issues:
- Did the Court of Appeals err in reducing the fine imposed by the CSC from P416,000.00 to P30,000.00?
- Was the CSC authorized to prescribe and impose a P1,000.00 per day fine for indirect contempt under its enabling powers?
Ruling:
The petition was granted. The Supreme Court modified the Court of Appeals' decision and reinstated the fine of P1,000.00 per day for four hundred sixteen days, or P416,000.00, as imposed by the CSC. The Court also held that the finding of guilt for indirect contempt had become final and could not be disturbed.
Ratio:
The Court reasoned that under Section 6, Article IX-A of the 1987 Constitution and Section 12(2), Title I(A), Book V of EO 292, the CSC may promulgate rules governing pleadings and practice and prescribe rules to carry into effect civil service laws, including contempt rules. The Rules of Court apply only suppletorily to quasi-judicial bodies per Section 12, Rule 71, so the CSC's Revised Rules on Contempt, which authorize a fine of P1,000.00 per day (Section 4), govern; the word "may" in the rule confers discretion, and given Eusebio's prolonged and bad-faith defiance for 416 days, the imposition of the maximum fine was reasonable and necessary to vindicate the CSC's authority and public interest.
Doctrine:
- The CSC may promulgate its own rules concerning pleadings and practice under Section 6, Article IX-A of the 1987 Constitution.
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