G.R. No. 228236 - House of Representatives Electoral Tribunal vs. Panga-Vega

On February 2, 2011, Atty. Daisy B. Panga-Vega, then Secretary of the House of Representatives Electoral Tribunal (HRET), requested a special leave of up to two months under Republic Act No. 9710 (Magna Carta of Women) to undergo a total hysterectomy.
On February 3, 2011, HRET approved her request, granting special leave not to exceed two months starting February 7, 2011.
On February 7, 2011, Panga-Vega underwent the surgery.

On March 7, 2011, after one month of leave, Panga-Vega informed HRET she was resuming duties and submitted a medical certificate (dated March 5) stating “no contraindication to resume light to moderate activities.”
On March 9, 2011, she provided a second certificate attesting she was “fit to work.”
On March 10, 2011, HRET directed her to consume the full two-month leave to ensure prolonged rest and to avoid stress due to a pending investigation into alleged tampering of minutes.

On March 14 and 24, 2011, Panga-Vega sought and was denied reconsideration by HRET, which cited her need for rest and confusion over her medical condition.
On April 13, 2011, she appealed to the Civil Service Commission (CSC) assailing HRET’s March 10 and 24 resolutions.
On October 9, 2012, the CSC granted her appeal, set aside HRET’s directive, and ordered payment of back salaries and benefits from March 7 to April 7, 2011, applying suppletory maternity leave rules.
On November 23, 2012 and February 12, 2013, HRET’s motions for reconsideration were denied by the CSC.

On March 19, 2013, HRET filed a petition for review with the Court of Appeals (CA).
On April 29, 2016, the CA dismissed the petition, affirming the CSC’s findings on leave benefits and suppletory application of maternity rules.
On November 8, 2016, the CA denied reconsideration.
On January 27, 2021, HRET filed this Petition for Review on Certiorari under Rule 45 before the Supreme Court.

Did HRET have the legal capacity to file the petition without express OSG deputation?
Can the rules on maternity leave under EO No. 292 be suppletorily applied to the special leave benefit under RA 9710?
Did Panga-Vega comply with the CSC Guidelines to return to work without exhausting her full two-month leave?