G.R. No. 101646 - Mantala vs. Salvador

In July 1988, Dr. Mariquita J. Mantala, a private medical practitioner, was given a temporary appointment as Division Chief, Medical Division III, Monitoring and Evaluation Division of the TB Control Service, Office of Public Health, Department of Health by the Secretary of Health.
The appointment was made despite Dr. Julia P. Regino being the next-in-rank employee, with the latter claiming that she was entitled to the position based on her 35 years of service and her holding the post of Medical Officer III.

Dr. Regino filed a formal protest with the Committee on Evaluation and Protest of the Department of Health.
The Committee ruled in favor of the Health Secretary’s decision, upholding Dr. Mantala’s appointment, despite Dr. Regino’s protest based on her next-in-rank status.

Dr. Regino appealed the Committee’s ruling to the Merit Systems Board of the Civil Service Commission.
On December 14, 1989, the Board rendered a decision in favor of Dr. Regino, adversely affecting Dr. Mantala’s appointment.
The Department of Health then appealed the Board’s decision to the Civil Service Commission.

On January 8, 1990, Secretary Bengzon made Dr. Mantala’s appointment permanent and later filed a motion for reconsideration of the Board’s decision—this motion was ultimately denied on February 12, 1990.
The Civil Service Commission, by Resolution dated June 14, 1990 (No. 90-553), dismissed the appeal by the Department of Health; however, on a subsequent motion for reconsideration, Resolution No. 90-1012 dated November 14, 1990, set aside the dismissal and upheld Dr. Mantala’s appointment.
The Commission declared that, on overall rating of qualification, attitude, and performance, Dr. Mantala outscored Dr. Regino, further supporting that the appointing authority is not confined solely to promotion by mere vacancy filling, but may consider civil service eligibility appropriate to the position.

On March 12, 1990, Dr. Regino instituted an action of quo warranto and mandamus in the Regional Trial Court at Quezon City, seeking to annul Dr. Mantala’s appointment and to have herself installed as Division Chief.
The Regional Trial Court rendered a judgment on August 30, 1991, which annulled Dr. Mantala’s appointment, ordered her removal, and directed the issuance of a promotional appointment in favor of Dr. Regino.

Despite her further motion for reconsideration, Dr. Regino’s challenge was denied by the Civil Service Commission, which maintained its Resolution No. 90-1012 in favor of Dr. Mantala.
The decision of the Commission became final and executory, thereby establishing a conclusive resolution of the personnel controversy.

Whether the Regional Trial Court was proper or had jurisdiction to rule on a dispute that primarily involved personnel actions and civil service appointments, which are within the exclusive purview of the Civil Service Commission.
Whether the filing of a quo warranto and mandamus action by Dr. Regino in the Regional Trial Court bypassed the established civil service adjudicatory process.

Whether the factual findings on qualification, attitude, and performance—as determined by the Civil Service Commission—should be subject to judicial review.
Whether the exercise of discretion by the appointing authority (in the context of civil service appointments) can be annulled on the basis of perceived alternative qualifications of another employee.