Title
University of the Philippines vs. Regino
Case
G.R. No. 88167
Decision Date
May 3, 1993
UP employee dismissed for exam leakage appealed to CSC, which ordered reinstatement. UP claimed autonomy, but SC upheld CSC's jurisdiction, affirming finality of its decision.

Case Digest (G.R. No. 178933)
Expanded Legal Reasoning Model

Facts:

  • Parties and Background
    • Petitioners:
      • University of the Philippines
      • UP School of Economics
    • Private Respondent:
      • Angel Pamplina, a mimeograph operator at the University of the Philippines School of Economics
    • Institutional Framework:
      • The University of the Philippines operates under its charter granted by Act 1870 (enacted June 18, 1908), which confers upon it academic freedom and institutional autonomy, including the power to appoint, compensate, and remove its employees for cause after due investigation and hearing.
      • Under the Civil Service Law (PD 807), administrative disciplinary cases involving civil service employees are under the appellate jurisdiction of the Civil Service Commission.
  • Sequence of Events
    • June 22, 1982 – Dismissal of Pamplina:
      • Pamplina was dismissed for dishonesty and grave misconduct after being found guilty of causing the leakage of final examination questions in Economics 106 taught by Prof. Solita Monsod.
    • Relief Seeking and Initial Proceedings:
      • After his dismissal, Pamplina’s appeal was denied by the UP Board of Regents.
      • He subsequently sought relief from the Merit Systems Board (MSB) under PD 1409, which has jurisdiction over administrative cases involving civil service employees.
      • UP moved to dismiss the MSB’s jurisdiction, relying heavily on precedent from University of the Philippines vs. Court of Appeals, positing that discipline cases fall solely under its autonomous control.
    • MSB and Civil Service Commission Actions:
      • On July 5, 1985, the MSB exonerated Pamplina and ordered his reinstatement with back wages.
      • UP’s motion for reconsideration with its Office of Legal Services was denied on January 10, 1986.
      • UP further appealed to the Civil Service Commission, which on November 4, 1987, issued Resolution No. 87-428 sustaining the MSB’s decision.
      • A subsequent motion for reconsideration filed on April 13, 1988, was also denied.
      • A second motion for reconsideration was filed on June 10, 1988, through new counsel from the Office of the Solicitor General, but was again denied on August 31, 1988, based on Section 39(b) of PD 807 allowing only one petition for reconsideration.
    • Judicial Relief and Final Developments:
      • Although Pamplina filed a Manifestation and Motion for Execution of Judgment on October 4, 1988, his reinstatement did not occur.
      • Pamplina then filed a petition for a writ of mandamus on November 11, 1988.
      • Judge Teodoro P. Regino of the Regional Trial Court of Quezon City granted the petition on April 27, 1989, ordering the immediate reinstatement of Pamplina with back wages and salaries for his period of preventive suspension.
      • On June 19, 1989, the petitioners elevated the issue by filing a petition for certiorari with the Supreme Court to annul the trial court’s decision and the orders of the Civil Service Commission, while also seeking the upholding of the UP President and Board of Regents’ decision dismissing Pamplina.
  • Statutory and Constitutional Context
    • Institutional Autonomy Versus Statutory Disciplinary Jurisdiction:
      • UP’s claim of exclusive disciplinary authority stems from Act 1870, which vests the UP Board of Regents with power over employee discipline based on internal procedures and hearings.
      • In contrast, PD 807 (Civil Service Law) expressly provides the Civil Service Commission with appellate jurisdiction over administrative disciplinary cases, including those involving UP employees.
    • Constitutional Provisions:
      • Under the 1972 Constitution, all government-owned or controlled corporations were part of the Civil Service.
      • The 1987 Constitution, specifically Article IX-B, Section 2(1), maintains that government-owned or controlled corporations with original charters, such as UP, fall within the scope of the Civil Service.
    • Procedural Timeliness:
      • The petitioners received the resolution denying their motion for reconsideration on April 22, 1988, thereby activating the reglementary 30-day period under Article IX-A, Section 7, of the 1987 Constitution.
      • Instead of filing directly to the Supreme Court within that period, the UP petitioners filed a second motion for reconsideration on June 10, 1988, which was 19 days beyond the reglementary period and not permissible under Section 39(b) of PD 807.
  • Conflicting Precedents and Their Applicability
    • The petitioners cited University of the Philippines vs. Court of Appeals (promulgated January 28, 1971) to argue for UP’s full disciplinary authority over its employees.
    • However, since PD 807 took effect only in 1975, that precedent is no longer applicable to the current statutory regime governing administrative disciplinary actions.

Issues:

  • Jurisdictional Conflict
    • Whether the Civil Service Commission has appellate jurisdiction over the disciplinary cases of UP employees, given UP’s institutional autonomy under Act 1870.
    • Whether UP, as a government-owned or controlled corporation with an original charter, is subject to the provisions of PD 807.
  • Timeliness of Relief and Procedural Violations
    • Whether the petitioners’ filing of a second motion for reconsideration beyond the 30-day reglementary period invalidates their procedural posture before the Supreme Court.
    • Whether the reglementary period should be considered as having run out after the first denial of reconsideration, thus precluding further appeals.
  • Applicability of Prior Jurisprudence
    • Whether the precedent established in University of the Philippines vs. Court of Appeals can justify UP’s claim for exclusive disciplinary authority, despite the later enactment of PD 807.
    • How the shift in statutory regime—from the Civil Service Law of 1959 to PD 807—affects the interpretation of disciplinary jurisdiction over UP employees.
  • Finality and Executory Nature of Administrative Resolutions
    • Whether the final and executory orders of the Civil Service Commission justify the issuance of a writ of mandamus directing Pamplina’s reinstatement.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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