Case Digest (G.R. No. L-10662) Core Legal Reasoning Model
Facts:
This case involves Roque Senarillos (petitioner and appellee) and Epipanio Hermosisima et al. (respondents and appellants), decided on December 14, 1956, by the Supreme Court of the Philippines. Roque Senarillos was appointed as the Chief of Police of Sibonga, Cebu, and served until January 2, 1952. On that date, following charges filed by Roque Geraldizo, Senarillos was suspended by the Municipal Mayor of Sibonga. The suspension was followed by an investigation and trial conducted by a “police committee” composed of three municipal councilors, created by Resolution No. 2, Series 1952 of the municipal council, instead of the entire municipal council as required under Republic Act No. 557. Despite Senarillos’ objection that the full council should conduct the investigation, the committee proceeded and issued an adverse decision on April 15, 1952, which was later signed by all council members. This decision was affirmed on appeal by the Commissioner of Civil Service in August 195
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Case Digest (G.R. No. L-10662) Expanded Legal Reasoning Model
Facts:
- Parties and background
- Roque Senarillos was appointed Chief of Police of Sibonga, Cebu, an appointment he held until January 2, 1952.
- On January 2, 1952, Senarillos was suspended by the Municipal Mayor of Sibonga following charges filed by Roque Geraldizo, which Senarillos denied.
- A "police committee" composed of three municipal councilors was created by Resolution No. 2, Series 1952, of the municipal council to investigate Senarillos.
- Investigation and suspension
- Despite Senarillos’ protest that the investigation should be conducted by the full municipal council as mandated by Republic Act No. 557, the committee held the investigation.
- On April 15, 1952, the committee issued an adverse decision against Senarillos, later signed by all council members.
- The Commissioner of Civil Service affirmed the decision on August 28, 1952, and the Civil Service Board of Appeals upheld it in October 1954.
- Subsequent suspensions and criminal case
- After the initial suspension period ended, Senarillos was again suspended based on an untried Administrative Case No. V-6. Upon expiry of this suspension, he was reinstated on May 25, 1952.
- On July 9, 1952, the Municipal Mayor filed a criminal swindling case against Senarillos and suspended him for a third time.
- The criminal case was dismissed on July 28, 1954.
- Legal proceedings initiated by Senarillos
- On April 27, 1955, Senarillos filed a petition with the Court of First Instance for relief, challenging his multiple suspensions and removal.
- The Court issued a writ of mandamus compelling the Municipal Mayor and Council to reinstate Senarillos as Chief of Police and declared his removal null and void.
- The court ordered payment of salary from January 3, 1952, and taxed costs against the respondents.
- Appeal and Supreme Court decision
- The Municipal Mayor and Council appealed the decision.
- The Supreme Court examined the legality of the investigation conducted by the "police committee" instead of the full municipal council.
Issues:
- Whether the investigation and removal of Roque Senarillos as Chief of Police conducted by a committee of the municipal council instead of the full council was valid under Republic Act No. 557.
- Whether the decisions of the Commissioner of Civil Service and the Civil Service Board of Appeals affirming the removal could validate the otherwise illegal investigation and removal.
- Whether Roque Senarillos committed laches in seeking relief from his removal and suspension.
- Whether Senarillos was entitled to reinstatement and back pay.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)