G.R. No. 172588 - Guzman vs. Guzman

On 8 September 2004, the petitioner was appointed as Provincial Agrarian Reform Officer II (PARO II) for the Department of Agrarian Reform in the Autonomous Region in Muslim Mindanao (DAR-ARMM) with Salary Grade 26.
His appointment was temporary, as he did not possess the required Career Service Executive Eligibility (CSEE) or Career Executive Service (CES) eligibility.
His temporary appointment was renewed on 8 September 2005.

On 24 October 2005, the petitioner requested the regional secretary of DAR-ARMM to change his appointment status from temporary to permanent.
His request was based on an RTC decision rendered in Special Civil Action No. 2005-085, where similar cases involving division superintendents had been granted permanent status.
The request was endorsed to the regional governor, who then forwarded the matter to the Civil Service Commission Regional Office No. XVI (CSCRO No. XVI) for favorable consideration.
The respondent, Grace Belgado-Saqueton, Director IV of CSCRO No. XVI, denied the request on two grounds:

The RTC decision was applicable only to the parties involved in that particular case.
The decision had already been submitted by the CSC to the courts for review.

Instead of elevating the case to the Civil Service Commission proper, the petitioner filed a special civil action for mandamus with the Regional Trial Court (RTC).
He invoked an exception to the doctrine of exhaustion of administrative remedies, arguing that the issue was purely legal.
His main contention was that since the PARO II position did not require CES eligibility (and was not declared a CES position), respondent could be compelled by mandamus to convert his status from temporary to permanent.

The RTC Branch 14 in Cotabato City took cognizance of the petition, maintaining its jurisdiction by asserting the presence of a pure legal question.
On 26 July 2006, the RTC issued an order directing the respondent to approve and attest to the petitioner’s permanent appointment, holding that respondent had neglected or refused her duty despite legal and factual mandates.
The court further justified its jurisdiction by stating that invoking the administrative remedy (via the CSC proper) would present a futile exercise if issues of law were to be settled definitively by the commission.
During the pendency of the case, on 22 June 2006, the Office of the Regional Governor appointed the petitioner to the same position on a permanent basis.
Respondent later moved for reconsideration, citing CSC Resolution No. 02-1011, which disapproves permanent appointments without CSEE or CES eligibility, and argued that the approval of an appointment involves a discretionary (not ministerial) duty.

The CA reversed the RTC orders dated 26 July 2006 and 7 August 2006.
It held that the petitioner had prematurely brought the case to the RTC without exhausting the available administrative remedies provided by the Civil Service Commission.
The CA traced the jurisdiction of the CSC proper over decisions of its regional offices to specific sections of the Revised Uniform Rules on Administrative Cases in the Civil Service and other related issuances (e.g., CSC Memorandum Circulars).
The CA denied the petitioner’s motion for reconsideration on the ground that the arguments were merely a rehash of previously raised issues.

The Supreme Court denied the Petition for Review filed by the petitioner, thereby affirming the CA decision.
It underscored that before court intervention is allowed, all administrative remedies must be exhausted as mandated by the enabling statutes.
The Court noted that the petitioner’s assertion of a purely legal issue was invalid because the matter also involved factual disputes regarding eligibility and qualification standards.
The decision contrasted this case with Buena, Jr. v. Benito, emphasizing that in the present case, the factual issues related to the qualification standards (CES or CSEE requirements) necessitated administrative resolution.
The Court reiterated the principle that the CSC is the sole arbiter of civil service controversies and that the doctrine of exhaustion of administrative remedies is foundational to administrative law in the Philippines.

Whether the petitioner’s filing of a petition for mandamus with the RTC was proper despite the availability of an administrative remedy through the Civil Service Commission proper.
Whether the issue of converting the petitioner’s appointment status from temporary to permanent constitutes a purely legal question or involves substantial factual determinations concerning eligibility.
Whether the petitioner’s failure to exhaust the available administrative remedies (by not filing an appeal with the CSC proper) was fatal to his cause.
The proper exercise of jurisdiction by the RTC and the subsequent reversal by the CA in light of the exhaustion doctrine.