Title
Tuazon, Jr. vs. Godoy
Case
G.R. No. 146927
Decision Date
Dec 10, 2002
The Supreme Court upheld the dismissal of allegations against NHA officials for dishonesty and misconduct in the Maharlika Village Project due to improper remedy and insufficient evidence.
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Case Digest (G.R. No. 146927)

Facts:

  • Marcelo G. Tuazon, Jr. and Rodolfo M. Agdeppa filed a petition for review on certiorari against Guillermo Godoy and Rommel Trinidad.
  • The case originated on February 2, 1995, when the National Housing Authority (NHA) approved Celcon Construction's bid, owned by Tuazon, for a two-storey building in Taguig, Metro Manila.
  • The project was contracted for 120 days at a cost of P704,951.15, with a formal contract signed on March 20, 1995.
  • During construction, Tuazon and Agdeppa faced challenges with NHA officials, particularly Godoy and Trinidad, who allegedly made unreasonable demands and withheld payments.
  • The NHA issued a warning letter on June 6, 1995, citing a work slippage of 17.24%.
  • The petitioners claimed that the respondents manipulated reports, hindering payment collection, leading to a halt in construction on October 1, 1995, due to financial issues.
  • On November 29, 1995, they filed a sworn statement with the Civil Service Commission (CSC) against Godoy and Trinidad for various misconducts.
  • The CSC dismissed the complaint on January 28, 1997, for lack of a prima facie case, a decision upheld by the Court of Appeals on April 26, 2000.
  • The petitioners' motion for reconsideration was denied, prompting the filing of a petition for review on certiorari.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of the respondents, affirming the Court of Appeals' decision.
  • The Court determined that the petitioners chose the incorrect remedy by filing a petition for certiorari instead of an appeal.
  • The CSC did not exhibit gra...(Unlock)

Ratio:

  • The Supreme Court highlighted that the petitioners improperly filed a petition for certiorari under Rule 65 instead of a petition for review under Rule 43, which is the appropriate remedy for appealing CSC decisions.
  • The Court reiterated that certiorari cannot replace a lost or lapsed appeal reme...continue reading

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