G.R. No. 207340 - Republic vs. Sandiganbayan, Special 2nd Division

Petitioner Dolores A. Paredes entered government service in July 1950 as a public school teacher.
She later transferred to the General Auditing Office as an Auditing Clerk detailed at the Philippine Tobacco Administration.
On November 16, 1977, she joined the then Human Settlements Regulatory Commission (HSRC) as Project Officer II.
Her career progression involved promotions: to H.S. Project Officer III in July 1980, to H.S. Project Officer II in December 1981, and she was extended a promotional appointment as H.S. Project Supervisor on October 1, 1985.

On December 30, 1985, private respondent Atty. Remedios A. Amor, then H.S. Project Officer IV, contested Paredes’ promotional appointment as H.S. Project Supervisor.
Amor contested on the ground that Paredes was not the "qualified next-in-rank" pursuant to Section 9 (16) and (20) of P.D. 807 and the Qualification Standards of the HSRC.
The matter was docketed as HSRC Protest Case No. 86-01.
The protest was later dismissed by HSRC Commissioner and Chief Executive Officer Ernesto C. Mendiola on procedural grounds, including the late filing of the protest and the fact that Amor was not among the top six candidates recommended by the Selection and Promotion Board.

Despite Amor’s protest, petitioner Paredes was eventually promoted: first extended as H.S. Project Supervisor effective October 1, 1985, and later elevated to the position of H.S. Program Coordinator effective August 17, 1987.
Subsequent to these appointments, private respondent Amor filed renewed protests, including a letter dated October 26, 1987, contesting Paredes’ qualifications for the higher position.
The controversy led to separate petitions for certiorari consolidated under G.R. No. 88177 (questioning the revocation of the appointment) and G.R. No. 89530 (concerning the administrative complaint against Amor).

On January 4, 1988, the MSPB rendered a decision reversing the earlier appointment decisions.

It found Paredes not qualified for the positions of H.S. Project Supervisor and H.S. Program Coordinator.
It ordered the revocation of her appointment and directed her reversion to her former position as H.S. Project Officer IV.

In the administrative complaint against Amor (filed by Paredes on May 7, 1986), the MSPB, after hearings and the submission of memoranda, absolved Amor of all charges except for habitual tardiness.
Amor was reprimanded and warned, as habitual tardiness was considered a light offense with insufficient evidence of prior warnings.

The public respondent CSC, in Resolution No. 89-072 dated February 1989, set aside the MSPB decision concerning Paredes’ appointment, declaring the position of H.S. Project Coordinator vacant.
Paredes’ subsequent motion for reconsideration was denied in Resolution No. 89-265 dated April 1, 1989.
In the administrative case filed against Amor, Paredes’ appeal to the CSC was dismissed in Resolution No. 89-276 dated April 27, 1989 on the ground that she was not the party adversely affected by the MSPB decision.
The CSC further dismissed her motion for reconsideration in Resolution No. 89-534 dated July 28, 1989, stressing that the complainant in such cases is relegated to the status of a witness rather than an appealable party.

On September 28, 1989, the Supreme Court, en banc, consolidated the cases and set the stage for the petition for certiorari by requiring the parties to file their memoranda within twenty days.
Petitioner Paredes raised the issue of an unapproved Qualification Standard being used as the basis for revoking and contesting her promotional appointments, and questioned the legality of the administrative proceedings involving Amor.

That the Qualification Standards, not being duly approved, could not serve as a basis for annulling promotional appointments.
That the public respondent acted with grave abuse of discretion amounting to lack of jurisdiction.
That her long years of public service and qualifications made her a suitable candidate for the promotions.

The evidence overwhelmingly established Amor’s guilt on multiple administrative charges.
The proceedings against Amor violated due process.
She was not precluded from disputing what she claimed were baseless and unlawful decisions by the respondent board.
That both the board and commission committed grave abuse of discretion, warranting the issuance of a writ of certiorari.

Whether the public respondent (CSC) committed grave abuse of discretion by sustaining the actions leading to the revocation of petitioner Paredes’ appointment as H.S. Project Coordinator and in declaring the position vacant, particularly given that an unapproved Qualification Standard was used as the basis for these decisions.

Whether petitioner Paredes, as the complainant in administrative proceedings, has the legal personality to appeal the MSPB’s decision in favor of private respondent Amor, who was the party adversely affected by the decision on charges—including habitual tardiness.