G.R. No. 87437 - Teotico vs. Agda, Sr.

Agda was appointed on January 2, 1984, by then FIDA Administrator Cesar Lanuza as CHIEF FIBER DEVELOPMENT OFFICER, a position not tied to any specific station.
By Special Order No. 29, series of 1984, he was designated as Acting Regional Administrator for FIDA Regions I and II, thereby assuming administrative responsibilities over these areas.
On November 13, 1987, through Special Order No. 219, Administrator Lanuza “temporarily re-assigned” Agda to the main office of FIDA to perform special functions, effectively detaching him from his acting regional assignment.

On December 11, 1987, Agda prepared and filed an urgent petition with the Civil Service Commission, the Secretary of the Department of Agriculture, and the Commission on Audit alleging that Special Order No. 219 was void due to lack of legal basis, violation of public interest, impropriety, moral defect, and breach of the rules on nepotism.
Despite his petition and subsequent administrative endorsements (by the Merit Systems Protection Board on January 21, 1988), Agda’s administrative remedy remained unresolved, prompting him to assert that his status quo had been disturbed.

On January 7, 1988, acting Administrator Teotico issued a memorandum requiring Agda to submit his development programs for Region I (1988–1993) as well as proposals on sericulture and the maguey industry.
Agda responded on January 12, 1988, indicating that since Special Order No. 219 had re-assigned him to the FIDA Central Office—where he remained—it would be in the service’s best interest to defer the submission of the required proposals, and he suggested reconsideration of the Special Order.
Teotico’s subsequent memorandum on March 2, 1988, demanded an explanation for Agda’s apparent absence, while later communications (including a routing slip dated March 11, 1988) ordered the turning over of keys to the regional safety vault.
On March 16, 1988, Agda acknowledged possession of the key but asserted his intention to withhold it pending resolution of his pending petition, thereby maintaining the status quo he sought to protect.

On March 23, 1988, Teotico formally charged Agda with insubordination and conduct prejudicial to the service for his failure to comply with earlier directives.
On April 4, 1988, Teotico placed Agda under preventive suspension in accordance with Special Order No. 74, citing grave misconduct, neglect of duty, and a pending investigation.
Agda sought relief by filing an amended petition for certiorari, prohibition, and injunction on April 18, 1988 in Civil Case No. 88-577, challenging Teotico’s actions, the issuance of the preventive suspension, and several subsequent orders—including the writ of preliminary injunction.
The lower court, in a series of orders (including a May 11, 1988 writ of preliminary injunction and later orders on December 16, 1988 and February 14, 1989), took actions that Agda claimed exceeded the judicial authority, essentially granting him reinstatement and the principal relief he sought.

Respondents, through Teotico and his co-respondents, filed various motions including a motion to dismiss based on the premise that Agda had not exhausted his administrative remedies.
Several motions for reconsideration and requests to declare contempt were also filed, with the court issuing a writ of preliminary injunction on May 11, 1988, and later a mandatory injunction ordering Agda’s reinstatement despite the lack of a full hearing.
Agda eventually appealed the court’s actions as being unauthorized judicial intervention in matters that should have been resolved administratively, highlighting that his administrative petition was still pending.

Issuing a writ of preliminary injunction without a proper evidentiary hearing.
Ordering the reinstatement of Agda with full back wages and allowances based solely on the pleadings and without adequately resolving the administrative dispute.

He failed to completely exhaust the available administrative remedies concerning his reassignment and suspension.
The administrative process, including his urgent petition with the Civil Service Commission, had not yet been fully resolved.

Whether Special Order No. 219 and subsequent administrative orders violated applicable civil service statutes and election-related restrictions:

The applicability of provisions in P.D. No. 807 (Civil Service Decree) regarding transfers or detailing of personnel.
Alleged violation of Section 261(h) of Batas Pambansa Blg. 881 concerning transfer or detail of civil service employees during the election period.

Whether the preventive suspension imposed on Agda was legally justified given the circumstances of his alleged insubordination and conduct.