Case Digest (G.R. No. 107590)
Facts:
Pamantasan ng Lungsod ng Maynila v. Civil Service Commission, G.R. No. 107590, February 21, 1995, the Supreme Court En Banc, Vitug, J., writing for the Court.The petition was brought by petitioner Pamantasan ng Lungsod ng Maynila (PLM) against the Civil Service Commission (CSC) and the Pamantasan ng Lungsod ng Maynila Faculty Organization (PLMFO) and sixteen individual faculty-members (private respondents). The case arose from a verified complaint for illegal dismissal and unfair labor practice filed on 29 May 1990 with the CSC by the sixteen faculty-members through PLMFO, after they received uniform notices dated 24 April 1990 advising that their temporary appointments would expire on 31 May 1990 and would not be renewed for School Year 1990–1991.
The CSC referred the case to the Public Sector Labor-Management Council (PSLMC) which deputized a hearing officer (Med-Arbiter Hope Ruiz-Valenzuela) and conducted non-adversarial proceedings under the Rules to Govern Government Employees’ Right to Self-Organization (including Secs. 3–5). In its Resolution dated 16 December 1991 (PSLMC Case No. 00-06-91), the PSLMC found that PLM committed an unfair labor practice and ordered reinstatement of the complainants; its denial of reconsideration followed on 30 April 1992 and the matter was transmitted to the CSC for “appropriate action.”
Concurrently, PLM had filed a certiorari petition against the PSLMC in G.R. No. 105157; that petition was dismissed by the Court in a Minute Resolution of 27 May 1992 for failure to comply with Circular 28-91 (certification against forum-shopping), and the dismissal became final and executory on 30 July 1992. Despite that, the CSC issued Resolution No. 92-814 dated 25 June 1992 sustaining the PSLMC findings and directing reinstatement with backwages; a motion for reconsideration was denied by CSC Resolution No. 92-1573 on 20 October 1992.
PLM then sought relief in this Court by a petition for certiorari under Rule 65 (though it had earlier mistaken its prior petition as Rule 45). The Court issued a temporary restraining order on 18 May 1993 enjoining the CSC from executing its resolutions. Procedurally, the petition was given due course and memoranda were ordered; the Solicitor General opposed CSC’s action as beyond CSC’s proper exercise of original ju...(Pro-only)
Issues:
- Did the CSC act with grave abuse of discretion, lack of jurisdiction, and denial of due process by adopting the PSLMC’s findings without affording PLM another opportunity to be heard?
- Did the CSC commit grave abuse of discretion by denying PLM the opportunity to present evidence to substantiate its defense against the illegal dismissal charge?
- Was the CSC’s direction to reinstate the faculty-members and to pay backwages improper because the respondents...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)