G.R. No. 248852 - Ferdez vs. Maaliw

On September 28, 1999, respondent Willie Fernando Maaliw filed a complaint against Danilo A. Longasa, alleging grave misconduct, oppression, dishonesty, negligence, and violation of RA 6713 and the Civil Service Law.
Longasa appeared and submitted his affidavit, and the complaint was set for decision on January 21, 2000.
More than 14 years later, on June 16, 2014, the CSC-NCR rendered a decision dismissing Maaliw’s complaint for being “insufficient in form.” This decision was signed by Director Lydia Castillo and prepared by Atty. Riza S. Fernandez.

Citing the delay in the resolution of the complaint, Maaliw filed a Complaint Affidavit dated November 9, 2015 against Fernandez and Dir. Castillo, alleging neglect of duty and violation of RA 6713.
In their Joint Comment filed on December 23, 2015, Fernandez and Dir. Castillo denied liability, arguing:

The complaint was already pending with the CSC-NCR before they assumed their respective positions.
The CSC-NCR, constrained by a heavy caseload and limited personnel, had met its annual targets despite the aged cases.
Maaliw had alternative remedies, such as filing a motion for reconsideration or appealing the decision, though records show no such motion was filed by him.

On August 31, 2016, the CSC dismissed Maaliw’s complaint against Fernandez and Dir. Castillo, recognizing the violation of Maaliw’s right to speedy disposition but attributing the 14-year delay to institutional challenges rather than the conduct of Fernandez or Dir. Castillo.
Maaliw moved for reconsideration, which was denied on December 16, 2016.
Subsequently, Maaliw elevated the matter by filing a Petition for Review on Certiorari with the Court of Appeals (CA).

The CA reversed and set aside the CSC’s decision and resolution.
A new decision was entered finding Fernandez and Dir. Castillo guilty of simple neglect of duty.
The CA imposed a fine equivalent to three months’ salary in lieu of suspension.

Fernandez subsequently sought reconsideration of the CA decision, which was denied for failure to advance substantial arguments or establish compelling grounds.

The CSC decision dismissing the complaint for lack of a prima facie case was final and not subject to appeal.
Maaliw lacked the requisite “personality” to appeal the CSC decision as he was not adversely affected by it.
The CA’s reversal and imposition of liability violated her right to due process since she had not been formally charged.
Her actions, including her prompt handling of Maaliw’s original complaint against Longasa, did not warrant a finding of neglect.

The petition raised questions of fact that should lead to its dismissal.
Fernandez’s defenses were insufficient and self-serving.
The CSC’s order requiring Fernandez and Dir. Castillo to file their comments was equivalent to a formal charge under the applicable rules.
He further requested the CA to implement its decision pending resolution of the petition and to investigate Fernandez for allegedly violating the canons of the legal profession.

Whether the CSC’s decision dismissing Maaliw’s complaint for lack of a prima facie case is appealable, and whether Maaliw possessed the requisite personality to elevate the issue before the CA.
Whether the CA erred in reversing the CSC’s decision and subsequently finding Fernandez (and Dir. Castillo) guilty of simple neglect of duty, particularly considering the absence of a formal charge and the denial of the full due process.
Whether it is proper to attribute the 14-year delay in the resolution of Maaliw’s complaint against Longasa to Fernandez’s alleged neglect of duty, given that she assumed her position after the complaint was already pending.