G.R. No. 194560 - Gadrinab vs. Salamanca

The case concerns the appointment of Joseph Raymond Mendoza as Chief of the Management and Information Systems Office (MISO) of the Supreme Court.
The matter arose from the submission and subsequent disapproval of Mendoza’s coterminous appointments by the Civil Service Commission (CSC).
The controversy centers on whether the procedures followed by the Office of the Administrative Services (OAS) under the supervision of Atty. Eden T. Candelaria complied with both the Court’s resolutions and the requirements imposed by the Civil Service Law and its rules.

On September 27, 2005, the Court en banc issued Resolution A.M. No. 05-9-29-SC, classifying positions such as the Chief of MISO as “highly technical or policy-determining.”
On March 14, 2006, the Court adopted qualification standards for the position, requiring, among others, a Bachelor’s Degree in Computer Science (or equivalent) with a Master in Science Degree in Computer Science or Information Technology.
On June 20, 2006, the Court lowered the educational requirement to a Bachelor’s Degree accompanied by a specified post-graduate credit load (at least 18 units) in Computer Science or Information Technology, though this revision was submitted pending CSC approval.

On August 8, 2006, in anticipation of CSC’s pending approval of the new standards, then Chief Justice Artemio V. Panganiban appointed Mendoza as MISO Chief with a coterminous appointment linked to his tenure.
Following Chief Justice Panganiban’s retirement, Chief Justice Reynato S. Puno directed a reappointment of Mendoza, this time for six months beginning on December 7, 2006.
On January 4, 2007, the OAS, headed by Atty. Candelaria, submitted these appointments (including the previous coterminous appointments) to the CSC for its approval.

On June 1, 2007, the CSC disapproved Mendoza’s coterminous appointments, stating that there was no record of the position being declared as primarily confidential, highly technical, or policy-determining to warrant such appointments.
The CSC’s decision rested on its interpretation of Section 12(9), Chapter 3, Book V of the Administrative Code and CSC Memorandum Circular No. 12, s. 2003, which provide that only positions so declared may be exempt from the usual qualification standards.
The CSC’s letter referenced prior representations and certifications provided by Atty. Candelaria regarding the classification of MISO Chief as highly technical, yet maintained that the necessary declaration by the Commission was lacking.

On June 12, 2007, Justice Antonio T. Carpio recommended disciplinary action against Atty. Candelaria for alleged:

Gross neglect of duty by submitting appointments to the CSC when such submission was not legally required.
Failure to inform the CSC Assistant Commissioner, in a prior meeting, that the position had been classified as highly technical or policy-determining.
Gross incompetence for indicating Mendoza’s appointment as “coterminous” with the term of the Chief Justice instead of stating it as a six‐month term per Chief Justice Puno’s instruction.

That submission to the CSC was done in strict compliance with the law and Civil Service rules.
That she had, in other documented communications (e.g., an official submission of the classification resolution and attached certification with the appointment papers), informed the CSC regarding the classification of the position.
That the use of the term “coterminous” was based on established practice and the recommendation of the Project Management Office (PMO) as well as Justice Carpio’s own earlier instructions.

Prior rulings such as Office of the Ombudsman v. Civil Service Commission and Paredes v. Civil Service Commission were cited to discuss:

The extent of CSC’s authority in reviewing appointments, particularly for positions classified as highly technical or policy-determining.
The ministerial duty of the CSC to approve appointments as long as the appointee meets the legal qualifications, regardless of debates on the nuances of classification.

The dispute also touched on the broader issue of judicial independence and whether unnecessary submission to CSC approval might undermine that independence.

Whether there are sufficient grounds to discipline Atty. Eden T. Candelaria for:

Submitting the appointments of Mendoza to the CSC for approval, despite the Court’s prior classification of the position as highly technical or policy-determining.
Failing to adequately inform the CSC Assistant Commissioner that the position of Chief of MISO was already classified as highly technical or policy-determining.
Erroneously indicating in the second appointment paper that Mendoza’s appointment was “coterminous” with the term of the Chief Justice rather than a six-month appointment as directed.

Whether Atty. Candelaria’s actions have undermined the independence of the judiciary by:

Deviating from established administrative practices concerning the submission of appointment papers.
Engaging in a meeting with the CSC Assistant Commissioner without sufficiently briefing the Court on its results, thereby raising concerns about possible sub rosa negotiations.

Whether the CSC’s disapproval of Mendoza’s appointments, based on the non-declaration of the position as primarily confidential, should impact the administrative liability of Atty. Candelaria.