Case Digest (G.R. No. 251903)
Facts:
Victoria M. Labastida v. Monina C. Quires, G.R. No. 251903, January 27, 2025, Supreme Court Third Division, Gaerlan, J., writing for the Court. Petitioner Victoria M. Labastida (then Municipal Planning and Development Officer of Saint Bernard, Southern Leyte) was charged by respondent Monina C. Quires with gross neglect of duty and conduct prejudicial to the best interest of the service arising from alleged failures to timely revise the LGU’s Comprehensive Land Use Plan, noncooperation in inquiries, refusal to attend a mandated training, disparaging social-media posts, and purportedly dishonestly rating her own performance.The Disciplining Authority initially rendered a Decision on June 18, 2015 dismissing Labastida. The Civil Service Commission (CSC) on March 14, 2016 set aside that Decision for lack of a formal charge and denial of due process, ordered reinstatement and backwages, and dismissed the complaint without prejudice to refiling. A new complaint was re-filed on May 2, 2016. The Disciplining Authority then issued another Decision on June 10, 2016, again finding Labastida guilty and dismissing her; a copy of this June 10, 2016 Decision was allegedly sent by registered mail and reflected a Registry Return Receipt No. 506 194 569 ZZ annotated “refused to accept 06-14-16.”
Labastida filed a Notice of Appeal on March 16, 2017, asserting she only received the June 10, 2016 Decision on March 8, 2017 when the Commission on Audit served her with a Notice of Suspension that included the Decision. The CSC dismissed her appeal as filed out of time in its December 19, 2017 Order (and denied reconsideration), relying on the registry return receipt to reckon the 15-day appeal period from June 14, 2016. Labastida petitioned the Court of Appeals (CA-G.R. CEB SP. No. 12157), but on April 10, 2019 the Court of Appeals affirmed the CSC, holding the registry return receipt raised the presumption of regular mailing and reception. The CA denied reconsideration on January 23, 2020.
Labastida filed a Petition for Review on Certiorari under Rule 45 to the Supreme Court. The Office of the respondent was later informed that Quires had di...(Pro-only)
Issues:
- Did the Court of Appeals err in holding that Registry Return Receipt No. 506 194 569 ZZ alone proved service by registered mail such that the 15-day appeal period under the RACCS ran from June 14, 2016, rendering petitioner's appeal untimely?
- If the presumption of regularity is rebutted, should procedural rules be relaxed so that petitioner's appeal be given due course and th...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)