Case Digest (G.R. No. 98120)
Facts:
Petitioner Filomena R. Mancita was appointed Municipal Development Coordinator of Pili, Camarines Sur on 1 August 1980. After Batas Pambansa Blg. 337 took effect, her position was abolished under a reorganization, and on 30 June 1985, Mayor Anastacio M. Prila appointed private respondent Prescilla B. Nacario as Municipal Planning and Development Coordinator effective 1 July 1985; Mancita later won reinstatement and back salaries from the Merit Systems Protection Board, as affirmed by the Civil Service Commission in Resolution No. 90-657 dated 16 July 1990.
Notwithstanding the CSC order for immediate implementation, Nacario filed with the Regional Trial Court of Camarines Sur, Branch 31 a petition for declaratory relief and prohibition with preliminary injunction (Civil Case No. P-1781) to declare the CSC and MSPB resolutions void and to restrain Mancita’s reinstatement and Nacario’s termination schedule. The RTC issued a temporary restraining order on 8 November 1990, denied Mancita’s motion to dismiss on 25 February 1991, and later denied reconsideration on 8 April 1991, prompting Mancita to file this petition for certiorari with TRO against the RTC orders.
Issues:
- Whether the RTC had jurisdiction in Civil Case No. P-1781 to review or nullify a final decision, order, or ruling of the Civil Service Commission.
- Whether the RTC orders issued in Civil Case No. P-1781 were void for lack of jurisdiction or for having been issued in excess of jurisdiction.
Ruling:
The Court granted the petition and annulled and set aside the RTC orders dated 8 November 1990, 25 February 1991, and 8 April 1991. The Court also made the earlier TRO permanent.
Ratio:
The Court held that a decision, order, or ruling of the Civil Service Commission is unappealable and reviewable only by the Supreme Court through certiorari under Rule 65 within the constitutional period. Relying on Lopez, Jr. vs. The Civil Service Commission, et al. and Section 7, Article IX, 1987 Constitution, the Court ruled that the RTC lacked jurisdiction over an action that effectively sought review of a CSC ruling.
Because Civil Case No. P-1781 aimed to declare the CSC and MSPB resolutions without force and legal effect, it necessarily constituted an unauthorized attempt to pass upon the CSC’s final determinations. Hence, the RTC acted without jurisdiction, rendering its questioned orders void.
Doctrine:
- The Civil Service Commission is the single arbiter of contests relating to the civil service, and its decisions, orders, or rulings are unappealable.
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