Case Digest (G.R. No. 113219)
Facts:
Aniceto G. Mateo, Maximo San Diego, Quirino Mateo, Daniel Francisco, and Leonila Kuizon, G.R. No. 113219, August 14, 1995, the Supreme Court Second Division, Puno, J., writing for the Court. Petitioners were members of the Board of the Morong Water District (MOWAD); private respondent Edgar Sta. Maria was MOWAD’s General Manager.Following complaints by some MOWAD employees, the Board (the petitioners) investigated Sta. Maria. On December 13–14, 1992 he was placed under preventive suspension and Maximo San Diego was designated Acting General Manager; Sta. Maria was later dismissed on January 7, 1993. On January 18, 1993 Sta. Maria filed a Special Civil Action for Quo Warranto and Mandamus with Preliminary Injunction (docketed Sp. Civil Case No. 014‑M) before the Regional Trial Court (RTC) of Rizal, Branch 78, asserting security of tenure and alleging denial of procedural due process and forcible exclusion from his office.
The petitioners moved to dismiss on two grounds: (1) the RTC lacked jurisdiction because disciplinary actions over government employees are vested exclusively in the Civil Service Commission (CSC); and (2) quo warranto was not the proper remedy. Judge Arturo A. Marave denied the motion to dismiss on April 26, 1993 and denied reconsideration on June 9, 1993. Petitioners filed a petition for certiorari under Rule 65 to the Supreme Court, which the Court referred to the Court of Appeals. The Court of Appeals (Sixteenth Division, chaired by Justice Jorge S. Imperial with Justices Eduardo G. Montenegro and Pacita Canizares‑Nye; ponente: Canizares‑Nye) dismissed the pe...(Subscriber-Only)
Issues:
- Did the Regional Trial Court of Rizal have jurisdiction to entertain Sp. Civil Case No. 014‑M involving the dismissal of an employee of a quasi‑public corporation?
- If the RTC lacked jurisdiction, was the Civil Service Commission the proper initial forum and what was the available appellate route f...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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