G.R. No. L-46218 - Madrigal vs. Lecaroz

On November 25, 1971, the public respondents—Governor Aristeo M. Lecaroz, Vice-Governor Celso Zoleta, Jr., and Provincial Board members Domingo Riego and Marcial Principe—abolished petitioner-appellant Joventino Madrigal’s position as a permanent construction capataz in the Provincial Engineer’s Office.
The abolition was effected through Resolution No. 204 from the annual Roads and Bridges Fund Budget for fiscal year 1971–1972, allegedly due to the province’s poor financial condition and the determination that his position was not essential.

On April 22, 1972, Madrigal filed an appeal to the Civil Service Commission challenging his removal.
He followed up on August 7, 1973, with another communication to the Commission regarding his appeal.
On January 7, 1974, the Commission, in its 1st Indorsement, declared his removal illegal.
Subsequently, on April 26, 1974, Governor Lecaroz sought reconsideration of the resolution abolishing Madrigal’s position, but the motion was denied by the Commission on February 10, 1975.

On August 4, 1975, Madrigal sent a letter to the Provincial Board seeking the implementation of the Commission’s resolution and his reinstatement.
On August 18, 1975, the Provincial Board, through Resolution No. 93, denied his request on the ground that his former position no longer existed.
In the same resolution, the Board ordered the appropriation of P4,200.00 as back salaries for the period from December 1, 1971, to June 30, 1973.

On December 15, 1975, Madrigal filed a petition before the Court of First Instance (now Regional Trial Court) of Marinduque seeking:

On March 16, 1976, the trial court dismissed the petition on the ground of laches, noting that the action was filed four years and twenty days after his removal.
The trial court underscored that actions for reinstatement must be filed within one (1) year from removal, citing established cases and doctrines.

Madrigal contended that the petition for mandamus and damages should not be dismissed as time-barred since:

The one-year period applicable to actions for quo warranto should not automatically apply to mandamus actions; and
The exhaustion of administrative remedies (his appeal to the Civil Service Commission) should toll or suspend the running of the prescriptive period.

Jurisprudence uniformly mandates a one-year filing period for both quo warranto and mandamus actions affecting public office; and
The pendency of an administrative remedy does not suspend the one-year period.

Whether the petition for mandamus and damages should be dismissed on the ground of laches even though the petitioner had an administrative remedy pending.

Did the one-year prescriptive period, originally fixed for actions for quo warranto, necessarily apply to an action for mandamus seeking reinstatement?
Does the exhaustion or pendency of an administrative remedy (i.e., the appeal to the Civil Service Commission) toll the running of the one-year period for filing a petition for reinstatement?

Whether the trial court erred in not proceeding with the trial on the merits to determine the claim for back salaries and damages, assuming arguendo that the petition for reinstatement was filed out of time.

Is the claim for back salaries and damages sufficiently independent to be tried separately from the reinstatement issue?
Can such claims stand in isolation when the principal action (reinstatement) has already been time-barred?