Mendoza vs. Allas

Facts:

Pedro Mendoza (petitioner) had a long career at the Bureau of Customs beginning in 1972 and, after reclassification, held the position of Director III, Customs Intelligence and Investigation Service (CIIS) by virtue of Civil Service reclassification pursuant to RA No. 6758 and National Compensation Circular No. 50; he discharged the functions of that office until March 1, 1988 when he was appointed Customs Service Chief of CIIS. In April 1993 Mendoza was temporarily designated Acting District Collector, Collection District X, Cagayan de Oro City, while Ray Allas (respondent) was designated Acting Director III of CIIS; Mendoza continued to receive Director III salary and benefits.

In March 1994 President Ramos appointed Ray Allas as Director III, CIIS; a letter dated September 1994 informed Mendoza that his services were terminated because of Allas' appointment. Mendoza demanded reinstatement but received no reply and on December 2, 1994 filed a quo warranto petition in the Regional Trial Court (RTC), Parañaque, Branch 258 (Civil Case No. 94-3078), seeking ouster of Allas and reinstatement with back wages.

On September 11, 1995 the RTC granted Mendoza's petition, finding that Mendoza was illegally terminated and that Allas usurped the office; the court ousted Allas and ordered Mendoza reinstated with full back wages and benefits. Allas appealed to the Court of Appeals (CA). While the appeal was pending, Allas was promoted on February 8, 1996 to Deputy Commissioner of Customs; Mendoza moved to dismiss the appeal as moot and the CA dismissed the appeal; the dismissal became final with entry of judgment on March 19, 1996.

Mendoza moved for execution of the RTC decision on May 9, 1996. On July 24, 1996 the RTC denied execution because the contested position was then occupied by Godofredo Olores, who was not a party to the quo warranto. Mendoza filed a special civil action for certiorari and mandamus before the CA (CA-G.R. SP No. 41801) seeking review of the RTC's denial of execution; the CA, in a November 27, 1997 decision (Abad Santos, Jr., J., ponente), dismissed Mendoza's petition. Mendoza then brought the present petition for review to the Supreme Court via Rule 45, seeking enforcement of the RTC judgment and payment of back salaries and benefits.

By the time the case reached the Court, Mendoza had reached compulsory retirement age on November 13, 1997 and thus sought, alternatively, payment of back sal...(Pro-only)

Issues:

• Does a judgment in quo warranto against a public officer bind his successor in office so as to permit execution of the judgment against a successor who was not a party to the quo warranto?
• Is petitioner entitled to payment of back salaries and other benefits by respondent Allas or by the Bureau of Customs when reinstatement is no longer possible due to petit...(Pro-only)

Ruling:

• (Pro-only)

Ratio:

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Doctrine:

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