G.R. No. 89376 - People vs. Lorenzo y De Ocampo

Eliseo A. Sinon, petitioner, filed a petition for certiorari challenging several resolutions issued by public agencies: the Civil Service Commission (CSC) and the Department of Agriculture Reorganization Appeals Board (DARAB).
The petition sought annulment of:

Resolution No. 97 dated August 23, 1989 by the DARAB which revoked petitioner Sinon's permanent appointment as Municipal Agriculture Officer (MAO) and appointed Juana Banan in his stead.
Resolution dated February 8, 1991 by the CSC which affirmed the DARAB resolution.
Resolution dated July 11, 1991 by the CSC denying Sinon's motion for reconsideration.

Prior to the reorganization, Juana Banan was the incumbent Municipal Agricultural Officer under the Ministry of Agriculture and Food (MAF).
Petitioner Sinon held the position of Fisheries Extension Specialist (FES) II with the Bureau of Fisheries and Aquatic Resources (BFAR) in Region II, Cagayan.
Executive Order No. 116 (January 30, 1987) reorganized the MAF into the Department of Agriculture (DA), necessitating the evaluation of employees for the 29 MAO positions in Region II, Cagayan.

A Placement Committee, as mandated by Republic Act No. 6656, prepared a list ranking the candidates for the MAO positions based on qualifications such as education, relevant experience, and eligibility.
In this initial list, petitioner Sinon was included and Juana Banan was excluded.
The Placement Committee’s evaluation awarded Sinon a rating of 60.66%.

After filing an appeal with the DARAB, Juana Banan obtained a re-evaluation of the initial rankings.
On August 23, 1989, the DARAB issued Resolution No. 97 re-evaluating the qualifications:

The revised ranking displaced petitioner Sinon, awarding Juana Banan a rating of 59.32% and Sinon a lower rating of 57.66%.

The Secretary of Agriculture, Carlos G. Dominguez, approved the re-evaluated results by affixing his signature on the same date.

Despite the re-evaluation, Sinon had already received an appointment as MAO for Region II in Cagayan on August 30, 1988, approved by Regional Director Gumersindo D. Lasam.
Sinon filed an appeal under Civil Service Case No. 573 on November 22, 1989 against the re-evaluation by the DARAB.

The appeal was initially granted on the grounds that DARAB had failed to file a timely comment and that evaluation of qualifications is best determined by the appointing authority.
As a result, a DARAB resolution dated February 28, 1989 was set aside.

Juana Banan filed a Motion for Reconsideration on March 19, 1990 to assert her qualifications versus Sinon's for the final slot among the 29 positions.
On February 8, 1991, the CSC, after reviewing DARAB’s previously unconsidered comment, granted Banan’s Motion for Reconsideration and thus affirmed her appointment.
Petitioner Sinon then filed a Motion for Reconsideration on March 21, 1991 challenging the CSC’s Resolution of February 8, 1991; however, the CSC denied this motion in its subsequent Resolution dated July 11, 1991.

The CSC’s Resolution of February 8, 1991 effectively nullified his earlier appointment made on August 30, 1989.
The CSC improperly reduced his rating from 60.66% to 57.66%, while increasing Juana Banan’s rating from 57.32% to 59.32%, thereby overstepping its review power and encroaching on the appointment authority.
The CSC’s actions amounted to the appointment of a substitute of its own choice, usurping the power reserved for the appointing authority.

The legally mandated process under RA 6656 and the administrative reorganization.
That the recommendations of the Placement Committee were merely consultative, while the final decision rested with the agency’s reorganization appeals mechanism, which was duly signed by the Secretary of Agriculture.

Whether the CSC committed grave abuse of discretion in revising and re-evaluating the ratings, thereby effectively annulling petitioner Sinon's appointment.

This includes the legality of reducing Sinon's rating from his initial evaluative score.
The issue centers on whether the CSC encroached upon the exclusive power of appointment vested in the appointing authority.

Whether the re-evaluation process, which displaced the findings of the Placement Committee, is consistent with the principles enshrined in Republic Act No. 6656.

The legal conflict between a recommendatory evaluation and the authoritative decision of the DARAB is in question.
Whether the actions taken by the Secretary of Agriculture and the subsequent affirmation by the CSC were proper and legally tenable.