G.R. No. 103068 - Meat Packing Corporation of the Philippines vs. Sandiganbayan

On November 11, 1988, the Civil Service Commission (CSC) received a letter from Efren L. Pagurayan alleging that petitioner Dennis C. Lazo boasted of having bought his career service (subprofessional) eligibility.
The letter specified that P7,000.00 was paid for the fraudulent eligibility, with P4,500.00 allegedly given to the examiner and computer programmers in the Manila Office and P2,500.00 to the Regional Office in Tuguegarao.

Acting on the report, the CSC directed its Regional Office at Tuguegarao on December 18, 1989, to investigate the matter.
The Regional Office determined that the complainant, Efren L. Pagurayan, was a fictitious individual and found no corroborative witnesses to support the allegation.
Consequently, on July 30, 1990, the Regional Office recommended dismissal of the administrative matter.

Due to the serious nature of the charge, the CSC ordered a retrieval and manual rechecking of Dennis C. Lazo’s examination answer sheets by its Office of Recruitment, Examination and Placement.
The recheck revealed a significant discrepancy: petitioner’s actual examination score was 34.48%, as opposed to the 76.46% stated in his certificate of eligibility.

Based on the rechecked results, the CSC charged petitioner with dishonesty, grave misconduct, and conduct prejudicial to the best interests of the service.
A formal investigation was ordered, but again the Regional Office, on July 24, 1991, recommended the dismissal of the administrative case due to a lack of evidence linking Lazo to the irregularity.
In Resolution No. 92-837 dated July 2, 1992, the CSC dismissed the administrative charges against petitioner but simultaneously revoked his certificate of eligibility for being null and void.

Petitioner filed a motion for reconsideration, contending that CSC acted in violation of due process by revoking his eligibility unilaterally without providing a formal investigation or the opportunity to inspect his answer sheet from the July 31, 1988, Civil Service Examination.
In Resolution No. 92-1975 dated December 1, 1992, the CSC responded by emphasizing that the correct rating (34.40% or 34.48%) as rechecked showed that petitioner had in fact failed the examination, rendering his earlier certificate erroneously issued and hence void.
The CSC maintained that as the central personnel agency, it was empowered to revoke a certificate of eligibility without further formal proceedings when the matter involved merely the reevaluation of existing records and application of a standard answer key.

Whether the unilateral revocation of petitioner’s certificate of eligibility by the CSC without a formal evidentiary hearing or notice violated his due process rights.
Whether petitioner’s right to be heard was infringed upon in the course of the administrative proceedings.

Whether the rechecking and manual reevaluation of petitioner’s examination answer sheets, conducted without his presence, was sufficient to establish the discrepancy between his actual score and the one printed on his certificate.
Whether the application of the rule of res ipsa loquitur in this context adequately justified the CSC’s decision to revoke the certificate without further investigation.

Whether a certificate of eligibility, if issued erroneously, creates any vested right in the petitioner for future appointment, despite subsequent revelations regarding his true examination performance.
Whether administrative actions taken on the basis of internal records (rechecked documents) can override the initial findings that resulted in the issuing of the certificate.