G.R. No. 113219 - Mateo vs. Court of Appeals

The case involved a dispute among employees of the Morong Water District (MOWAD), a quasi-public corporation created under Presidential Decree No. 198.
Petitioners, composed of several Board Members of MOWAD, initiated an investigation against private respondent Edgar Sta. Maria, who was serving as the General Manager.

On December 13, 1992, following complaints by some MOWAD employees, private respondent Edgar Sta. Maria was placed under preventive suspension.
Maximo San Diego was designated as Acting General Manager, and subsequently, Edgar Sta. Maria was dismissed on January 7, 1993.

On January 18, 1993, Edgar Sta. Maria filed a Special Civil Action for Quo Warranto and Mandamus with a preliminary injunction before the Regional Trial Court (RTC) of Rizal, Branch 78.
The petition incorporated three causes of action:

The first cause centered on his having security of tenure since August 1984, arguing that any removal, temporary or permanent, was only permissible for cause and after full compliance with due process requirements.
The second cause claimed that his dismissal was the result of a conspiracy involving petitioners and other Board members, further alleging that an order from petitioner Aniceto G. Mateo effectively terminated his services.
The third cause sought to restrain the respondents from preventing Edgar Sta. Maria from exercising his rights and duties as General Manager.

That the RTC had no jurisdiction over disciplinary actions involving government employees, which fall under the exclusive jurisdiction of the Civil Service Commission (CSC).
That quo warranto was not the appropriate remedy for the matter at hand.

The Regional Trial Court, through Judge Arturo Marave, denied both the Motion to Dismiss (April 26, 1993) and the Motion for Reconsideration (June 9, 1993).
The matter was subsequently elevated to the Supreme Court via a petition for certiorari under Rule 65, with the case being referred to the Court of Appeals.
The Court of Appeals, in its Decision dated November 24, 1993, dismissed the petition for lack of merit and denied the Motion for Reconsideration on January 11, 1994.

Whether the Regional Trial Court of Rizal had jurisdiction over a Special Civil Action (Sp. Civil Case No. 014-M) involving the dismissal of an employee of a quasi-public corporation such as MOWAD.

Whether the remedies presented by private respondent (quo warranto and mandamus) were appropriate under the circumstances, particularly in relation to the protections provided by the Civil Service Law.

Whether the disciplinary action, including punitive measures such as preventive suspension and termination, fell under the ambit of the Civil Service Law and the established administrative procedures that govern employees of government-owned and controlled corporations.