Title
Manaois vs. Brown
Case
G.R. No. L-32191
Decision Date
Jul 30, 1971
Carlos Manaois, City Engineer of Basilan, was ordered transferred due to strained relations with the mayor. Despite turning over his office, he remained incumbent pending transfer and was entitled to his salary, as ruled by the Supreme Court.

Case Digest (G.R. No. L-32191)

Facts:

Carlos C. Manaois was appointed City Engineer of Basilan City on July 17, 1963, with his appointment confirmed by the Commission on Appointments on May 30, 1964. Subsequently, an administrative case was initiated against him by the City Mayor, leading the Commissioner of Public Highways to summon him to the central office in Manila on August 1, 1967. On November 19, 1968, the administrative case was resolved in Administrative Order No. 149 issued by the Office of the President. The order stated that due to the gravity of the offense and strained relations with his superior, petitioner was to be transferred to another city for the general interest of service. Accordingly, on November 28, 1968, the Commissioner directed him to Basilan City to effect the turnover of his office to officer-in-charge Leopoldo Manapol and to conduct a complete clearance of his money and property accountability, which he did on January 15, 1969. However, on January 29, 1969, the City Treasurer—with the concurrence of the City Mayor—declared petitioner to have effectively ceased to be City Engineer and refused to pay his corresponding salary. In contrast, both the Commissioner’s central office and the Auditor General maintained that petitioner's temporary assignment in Manila did not constitute abandonment of his post, and that pending his transfer no change had been made in his status as City Engineer.

Issues:

  • Whether petitioner’s compliance with the directive to turn over his office and clear his accountability, as ordered in connection with his administrative reassignment, amounted to an abandonment of his post as City Engineer.
  • Whether, pending his formal transfer by the President’s authority, petitioner remained entitled to receive the salary due to his position as City Engineer of Basilan City.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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