Case Summary (G.R. No. L-34952)
Background Facts
Pulido was appointed as Chief Deputy Sheriff in 1969 and later designated as executive sheriff and court liaison officer by the Municipal Board in early 1970. In February 1972, he was charged with engaging in partisan political activities, leading to his suspension by Mayor Bagatsing shortly after he assumed office. Pulido contested the suspension and sought legal remedy through a petition for certiorari and prohibition against the Mayor and his investigators, asserting that the Mayor lacked authority over the sheriff's office.
Lower Court Proceedings
In March 1972, the Court of First Instance ordered Pulido's reinstatement and temporarily restrained the administrative investigation initiated by the Mayor's office. Subsequent motions for reconsideration filed by Bagatsing and his investigators were denied. The Mayor and his associates then sought relief from the Supreme Court to annul the reinstatement order and the injunction against the administrative investigation.
Legal Arguments
Pulido argued that the Mayor lacked jurisdiction over the sheriff's office, which should be governed by judicial authority or the Department of Justice. In contrast, Mayor Bagatsing claimed that his office had the power to appoint, investigate, and discipline city employees, including those in the sheriff's office, as vested by the City Charter.
Court's Rationale
The lower court justified reinstating Pulido on the basis that the executive sheriff was a ministerial officer whose removal would impair the functioning of the court system. The court also expressed concern over the Mayor's dual role as both the offended party and investigator in the matter, implying a violation of due process.
Resignation and Mootness
On October 9, 1972, Pulido submitted his resignation, which the Mayor later accepted. This development raised questions about the relevance of the ongoing legal proceedings. The parties acknowledged the case's potential mootness; however, they disagreed on the reasons for it. Pulido contended that his case could remain valid due to the changes in administrative supervision and the judicial authority established by the new Constitution.
Issues Concerning Jurisdiction and Authority
Central to the legal dispute was the issue of authority over Pulido's employment. While Pulido sought to assert his position as a judicial officer under the supervision of the Secretary of Justice, the Court reasoned that he was, in fact, a city employee appointed by the Mayor, thus subject to the
...continue readingCase Syllabus (G.R. No. L-34952)
Case Background
- The case revolves around the reinstatement of Vicente S. Pulido to his position as executive sheriff and court liaison officer of the sheriff's office in Manila.
- Pulido was initially appointed by Mayor Antonio J. Villegas on December 23, 1969, and was later designated as executive sheriff on February 24, 1970, which included a salary increase to P20,000 per annum.
- Pulido's previous role was as branch clerk of court in the Court of First Instance of Manila.
Administrative Charges and Suspension
- On February 1, 1972, Pulido faced administrative charges from eight employees alleging his involvement in partisan political activities during the 1971 elections.
- Following these charges, Mayor Ramon D. Bagatsing, who succeeded Villegas, suspended Pulido on February 15, 1972.
- Pulido filed a petition for certiorari and prohibition seeking reinstatement and to restrain the administrative investigation.
Initial Court Proceedings
- The Court of First Instance of Manila ruled in Pulido's favor on March 11, 1972, ordering his reinstatement and restraining the administrative investigation, declaring such investigation violated due process.
- After Pulido posted bonds, the court issued additional orders on March 13, 1972, reinforcing the reinstatement and restraining the investigation.
Appeals and Counterarguments
- Bagatsing, Carmelo, and Pimentel filed special civil actions of certiorari and prohibition against the lower court's orders on April 11, 1972.
- The petitioners argued that the Mayor has the authority to appoint, investigate, and remove the personnel from the sheriff's office, citing provisions from the City Charter and the Civil Service Law.