Facts:

The case involves Hon. Erlinda C. Pefianco, in her capacity as Secretary of the Department of Education, Culture and Sports (DECS), as the petitioner against Maria Luisa C. Moral, the respondent, who was the Chief Librarian of the Catalog Division of the National Library. The events leading to the case began on July 26, 1994, when then DECS Secretary Ricardo T. Gloria filed a complaint against Moral for dishonesty, grave misconduct, and conduct prejudicial to the best interest of the service. The complaint alleged that Moral had pilfered historical documents from the Filipiniana and Asian Division (FAD) vaults of the National Library, which were under her supervision, and that she unlawfully retained possession of 41 missing items.

An Investigating Committee from DECS conducted hearings on the complaint, with Atty. Jose M. Diaz representing the DECS Secretary and Moral being represented by her private counsel. On September 25, 1996, Secretary Gloria issued a resolution fin...

Facts:

1. Administrative Complaint: On 26 July 1994, former DECS Secretary Ricardo T. Gloria filed a complaint against Maria Luisa C. Moral, Chief Librarian of the National Library, for dishonesty, grave misconduct, and conduct prejudicial to the best interest of the service. The complaint alleged that Moral pilfered historical documents from the Filipiniana and Asian Division (FAD) vaults and kept 41 items in her possession without legal authority.
2. Investigation and Resolution: The DECS Investigating Committee conducted hearings, and on 25 September 1996, Secretary Gloria issued a resolution finding Moral guilty of the charges. She was dismissed from service with forfeiture of retirement benefits. Moral received the resolution on 30 September 1996 but did not appeal.
3. Request for Investigation Report: On 2 October 1996, Moral filed a petition for the production of the DECS Investigation Committee Report, which was denied. She reiterated her request, but Secretary Gloria denied it again on 23 October 1996.
4. Mandamus Case: Instead of appealing the dismissal, Moral filed a mandamus case in the regular courts, seeking to compel Secretary Gloria to furnish her with the investigation report and to enjoin the enforcement of her dismissal. Secretary Gloria moved to dismiss the case, but the trial court denied the motion.
5. Appeal to Court of Appeals: Secretary Gloria elevated the case to the Court of Appeals, which dismissed his petition for certiorari, ruling that he acted prematurely by not filing a motion for reconsideration before the trial court.
6. Substitution of Parties: Secretary Gloria was replaced by Secretary Erlinda C. Pefianco, who was substituted as the petitioner in the case.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Procedural Rule on Motions to Dismiss: Under Rule 16, Section 3 of the 1997 Rules of Civil Procedure, a court must clearly and distinctly state the reasons for denying a motion to dismiss. The trial court’s failure to do so rendered its order a patent nullity, justifying direct recourse to certiorari without first filing a motion for reconsideration.
2. Nature of Mandamus: Mandamus lies only to compel the performance of a ministerial duty, not a discretionary one. Moral failed to demonstrate a clear legal right to the investigation report or a ministerial duty on the part of the DECS Secretary to furnish it.
3. Finality of Administrative Decision: Moral’s failure to appeal her dismissal to the Civil Service Commission rendered the DECS resolution final and executory. There was no legal basis to compel the production of the investigation report, as it was an internal and confidential document.
4. Grave Abuse of Discretion: The trial court’s denial of the motion to dismiss constituted grave abuse of discretion because it failed to comply with procedural rules and because the mandamus case lacked a cause of action.