G.R. No. 251903 - Labastida vs. Quires

Respondent Monina C. Quires filed an administrative complaint against petitioner Victoria M. Labastida, then Municipal Planning and Development Officer (MPDO) of Saint Bernard, Southern Leyte, for gross neglect of duty and conduct prejudicial to the best interest of the service.
The complaint alleged that Labastida failed to timely and properly revise the LGU’s Comprehensive Land Use Program (CLUP) as directed by the Municipal Mayor and submitted an incomplete CLUP that included "copy-paste" materials.
Additional charges included refusal to cooperate in an inquiry, disrespectful communications, failure to attend official training, inappropriate social media posts, and dishonest performance evaluations.

On June 18, 2015, the Municipal Mayor's office dismissed Labastida for the charges.
Labastida appealed to the Civil Service Commission (CSC), which on March 14, 2016, reversed the dismissal, finding due process violations due to lack of formal charges and opportunity to respond.
The complaint was dismissed without prejudice and Labastida was reinstated with backwages.

The complaint was re-filed on May 2, 2016.
On June 10, 2016, the Disciplining Authority again found Labastida guilty and imposed dismissal with forfeiture of benefits and disqualification from public office.
The decision was sent by registered mail but was noted as "refused to accept 06-14-16".

Labastida filed a Notice of Appeal on March 16, 2017, alleging actual receipt of the June 10, 2016 Decision only on March 8, 2017.
The CSC dismissed the appeal as filed out of the 15-day period reckoned from June 14, 2016, based on the registry return receipt.
The Court of Appeals (CA) affirmed the dismissal, applying the presumption of regularity of mail service.

Labastida contested the CA ruling, claiming no receipt of the decision in June 2016 and presented evidence that there were no official records of the decision in the Municipal Mayor’s office.
The Supreme Court noted the death of the respondent Quires and proceeded without opposition.

Whether the CA erred in ruling that Labastida’s appeal was filed out of time based on presumed receipt of the June 10, 2016 Decision on June 14, 2016.
Whether the registry return receipt alone is sufficient proof of service of the decision by registered mail.
Whether the procedural rules should be relaxed in favor of substantial justice, allowing the appeal to be given due course.