G.R. No. 136592-93 - People vs. Pancho

Case Summary (G.R. No. 136592-93)

Case Background and Factual Summary

In 2005, respondents Guevarra and Cezar were top officials of PUP. Honesto L. Cueva, as PUP Chief Legal Counsel, filed an administrative complaint against them alleging gross dishonesty, grave misconduct, falsification of official documents, conduct prejudicial to the best interest of service, notorious undesirability, and violation of Section 4 of R.A. No. 6713. The falsification charge stemmed from Guevarra’s submission of a bond application indicating he had no pending criminal or administrative cases, despite both officials having 17 pending Sandiganbayan cases for alleged violations of R.A. No. 3019. Cezar endorsed the approval despite this knowledge. Respondents claimed their negative response to pending cases meant no final conviction existed and thus was made in good faith.

Administrative Proceedings Before the Civil Service Commission

The CSC, upon prima facie finding, formally charged Guevarra with dishonesty and Cezar with conduct prejudicial to the service. Respondents moved to dismiss the case or suspend proceedings, while Cueva sought preventive suspension and inclusion of additional charges. The CSC denied the motions but suspended Guevarra for 90 days on preventive grounds due to his influential position. Respondents assailed the CSC’s jurisdiction, petitioning the Court of Appeals (CA), which ruled the CSC acted without jurisdiction. The CA held that the PUP Board of Regents (BOR) has exclusive disciplinary jurisdiction according to Section 47 of the Administrative Code, and that Cueva, being a PUP employee, should have exhausted remedies with the BOR prior to the CSC.

Issue on Jurisdiction of the Civil Service Commission

The central issue is whether the CSC possesses original concurrent jurisdiction with the governing boards of chartered state universities over administrative complaints filed directly with it, especially when such complaints are initiated by public employees rather than private citizens.

Supreme Court’s Ruling on CSC’s Jurisdiction

The Supreme Court granted the petitions and reversed the CA ruling, holding that the CSC has original concurrent jurisdiction with the BOR of state universities in administrative disciplinary cases. The Court noted:

The 1987 Constitution includes government-owned or controlled corporations with original charters, such as PUP, within the civil service.
Section 47 of the Administrative Code grants the CSC appellate jurisdiction over disciplinary cases and original jurisdiction when a complaint is filed directly with it by a private citizen. However, the Court rejected the CA’s restrictive interpretation limiting direct CSC filing only to private citizens, finding it unreasonable and contrary to legislative intent.
The CSC may hear and decide cases instituted or brought before it directly or on appeal, without limitation on who may file the complaint.
Jurisprudence, including Camacho v. Gloria and Hilario v. Civil Service Commission, affirms CSC’s authority to assume jurisdiction over cases filed directly with it, even if complainants are government employees.
The Uniform Rules on Administrative Cases (Civil Service Rules) support CSC’s original jurisdiction and concurrent jurisdiction with heads of agencies, such as university boards.
The doctrine that CSC jurisdiction is exclusively appellate when complaint is filed by a government official conflicts with statutory mandates and undermines CSC's supervisory role.
Cases like Civil Service Commission v. Alfonso and Civil Service Commission v. Sojor confirm that legislative grants of disciplinary authority to governing boards do not divest CSC of jurisdiction but are concurrent with it.
The Court further held that the passage of R.A. No. 8292, which empowers governing boards to discipline school officials and employees, does not repeal or conflict with E.O. No. 292 or the CSC’s jurisdiction. Harmonious reading of the laws shows concurrent jurisdiction, not exclusivity.
The CA’s reliance on Gaoiran v. Alcala was misplaced as that case pertained to a complaint against a public school teacher under a different disciplinary scheme and did not negate CSC’s jurisdiction over university officials.
To forestall administrative burdens, the Court emphasized that CSC may choose to deputize the board or other agencies to conduct investigations, thereby managing case volume. Moreover, original concurrent jurisdiction means if the BOR exercises jurisdiction first, CSC’s jurisdiction is deferred.

Legal Principles Established

Scope of Civil Service
The civil service under the 1987 Constitution includes government entities with original charters such as PUP, making their employees subject to CSC jurisdiction.
Jurisdictional Authority

CSC has original and appellate jurisdiction over administrative disciplinary cases involving government employees and officials, regardless of whether the complaint is filed by a private citizen or another government employee.
Governing boards of state universities and colleges also have disciplinary authority over their officials and employees, but this jurisdiction is concurrent, not exclusive.
A complaint by a government employee filed directly with the CSC is valid and falls within CSC’s original jurisdiction.

Statutory Interpretation

The literal interpretation of limiting direct CSC complaint filing to private citizens is rejected for being unjust and impractical.
Laws granting disciplinary power to governing boards must be harmonized with CSC’s jurisdiction; neither law repeals the other by implication.
Administrative rules do not have power to amend substantive law or expand jurisdiction beyond statutory grants.

Jurisdictional Submission and Estoppel
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Case Syllabus (G.R. No. 136592-93)

Background and Parties Involved

The case involves consolidated petitions for review under Rule 45 challenging the December 29, 2006 Decision of the Court of Appeals (CA) regarding the jurisdiction of the Civil Service Commission (CSC) over an administrative complaint.
Respondents Dante G. Guevarra and Augustus F. Cezar held key administrative positions at the Polytechnic University of the Philippines (PUP) in 2005 as Officer-in-Charge/President and Vice-President for Administration, respectively.
Petitioner Honesto L. Cueva, then Chief Legal Counsel of PUP, filed an administrative complaint against respondents alleging gross dishonesty and related offenses under civil service laws.
The complaint centered on Guevarra’s alleged falsification of an official document (Application for Bond of Accountable Officials and Employees of the Republic of the Philippines) by denying the existence of pending criminal and administrative cases despite known pending cases before the Sandiganbayan.

Facts of the Case

Guevarra answered "NO" to a question in the bond application regarding criminal or administrative records, despite having 17 pending cases for violation of R.A. No. 3019 alongside Cezar.
Cezar endorsed and recommended approval of the bond application, fully aware of the pending cases.
Both respondents argued that “criminal or administrative records” in the application pertained only to final convictions, not pending cases, and thus answered truthfully.
The CSC found prima facie evidence of civil service violations and issued formal charges against Guevarra and Cezar in March 2006.
Respondents moved for reconsideration and suspension of the case, while Cueva moved for preventive suspension and inclusion of further charges.
CSC denied reconsideration and motions for additional charges but imposed a 90-day preventive suspension on Guevarra.
Guevarra and Cezar filed a petition before the CA questioning CSC’s jurisdiction, prompting the CA to nullify CSC’s resolutions for lack of jurisdiction in December 2006.

Issue Presented

Whether the Civil Service Commission possesses original concurrent jurisdiction over administrative cases that fall under the jurisdiction of heads of agencies, specifically regarding officials of chartered state universities such as PUP.

Legal Principles Governing CSC Jurisdiction

The CSC is the central personnel agency of the government, empowered by the Administrative Code of 1987 (Executive Order No. 292) and constitutional provisions to discipline government employees, including those in government-owned or controlled corporations with original charters like PUP.
Section 47, Chapter 7 of E.O. No. 292 provides that:
- CSC has appellate jurisdiction over administrative disciplinary cases involving penalties more severe than 30-day suspension or fines exceeding 30 days’ salary.
- CSC may also hear cases filed directly by private citizens against government officials, with the option to deputize investigating agencies.
- Heads of agencies and instrumentalities have original jurisdiction to discipline their officers and employees with finality for penalties not exceeding 30 days’ suspension or fines.
The Uniform Rules on Administrative Cases in the Civil Service clarify CSC’s authority to hear and decide administrative cases instituted or brought to it directly or on appeal.

Court’s Rationale and Holding

The Court ruled that the CSC indeed has original concurrent jurisdiction with the Board of Regents of PUP over administrative cases filed directly with it, irrespective of whether the complainant is a private citizen or a member of the civil service.
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