Case Digest (G.R. No. L-62133)
Facts:
Editha L. Lira v. Hon. Civil Service Commission and Brenda Jaranilla, G.R. No. 62133, September 30, 1986, the Supreme Court En Banc, Fernan, J., writing for the Court.Petitioner Editha L. Lira was an employee of the Iloilo City government serving as Barangay Field Coordinator and was detailed to the Budget, Fiscal Management and Fiscal Research Division of the Office of the City Mayor from August 7, 1978 until she was appointed by the Mayor as Budget Officer of Iloilo City effective January 1, 1979 (appointment signed February 1, 1980). Private respondent Brenda R. Jaranilla was Chief, Budget Operations Division, Office of the City Treasurer since June 2, 1975 and was later appointed Internal Auditor effective January 1, 1979 (appointment dated February 18, 1980).
In 1979 Iloilo City adopted a Position Classification and Pay Plan (PCPP) pursuant to Presidential Decree No. 1136, which reclassified Lira’s position to Budget Officer and reclassified Jaranilla’s post to Internal Auditor. Subsequently, by LOI No. 1039 (June 19, 1980) implementing P.D. 1375, the City Mayor issued a Notice of Salary Adjustment (effective January 1, 1980) raising Lira’s pay to that of a City Budget Officer. On November 18, 1980 Jaranilla filed a protest with the Civil Service Regional Office No. VI contesting Lira’s notice of salary adjustment and asserting that the City Budget Officer position created under P.D. 1375 should properly be filled from the Local Budget Staff (i.e., personnel like herself) and that Lira’s appointment lacked a legal basis.
The City Mayor dismissed Jaranilla’s protest. Jaranilla appealed to the Civil Service Merit System Board which, in a decision dated September 3, 1981, declared null and void the notice of salary adjustment issued to Lira and ordered that Jaranilla — found more qualified on a comparative review of education and relevant experience — be appointed City Budget Officer. The Merit System Board denied Lira’s motion for reconsideration on February 15, 1982. Lira appealed to the Civil Service Commission which, by Resolution No. 82-563 dated June 2, 1982 (and denied reconsideration August...(Pro-only)
Issues:
- Was petitioner Editha L. Lira’s appointment to the reclassified position of Budget Officer in substantial compliance with the requirements for appointment to the City Budget Officer created under P.D. 1375 and LOI No. 1039?
- Did the Civil Service Merit System Board and the Civil Service Commission commit arbitrariness or grave abuse of discretion in declaring the notice of salary adjustment null and void and ordering the appointment of Brenda R. Jaranilla?
- Is private respondent Brenda R. Jaranilla estopped from claiming the City Budget Officer position because she...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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