Case Summary (G.R. No. 211077)

Voluntary Separation from Service

• Public officers and employees who voluntarily resign or retire cannot later demand reinstatement or backwages.
• Such individuals affirm their separation from service through their actions, especially when done to avoid administrative liability.
• The principle emphasizes that one cannot return to a position they willingly left, particularly when the departure was intended to evade consequences.

Consolidated Petitions Overview

• The case involves two consolidated petitions for review from the Civil Service Commission and the Province of Misamis Oriental.
• Both petitions challenge the Court of Appeals' decisions that ordered the reinstatement of Gabriel Moralde and the payment of backwages.
• The Court of Appeals had set aside previous Civil Service Commission resolutions that denied Moralde's reinstatement.

Background of Moralde's Employment and Misconduct

• Gabriel Moralde was employed as a Dental Aide and was charged with falsifying his Daily Time Records.
• He admitted to not rendering service during specific periods and had a history of misconduct, including previous infractions.
• While facing administrative charges, Moralde applied for retirement benefits without informing his employer.

Administrative Proceedings and Retirement Application

• Following Moralde's application for retirement, he was dismissed for falsification the day after his retirement application was filed.
• He appealed his dismissal to the Civil Service Commission, claiming it violated due process.
• The Civil Service Commission later ruled in his favor, ordering reinstatement, unaware of his retirement status.

Discovery of Retirement and Subsequent Actions

• The Province discovered Moralde's retirement status while processing his reinstatement, leading to a motion for modification of the judgment.
• The Civil Service Commission declared Moralde's reinstatement moot, recognizing that he had voluntarily left his position.
• Moralde's actions were seen as an attempt to avoid the consequences of his misconduct.

Legal Principles on Finality of Judgments

• The doctrine of immutability of final judgments prevents modifications once a decision becomes final and executory.
• Exceptions exist for clerical errors, void judgments, or supervening events that render execution unjust.
• The Civil Service Commission's decision to declare Moralde's reinstatement moot was consistent with this doctrine.

Moralde's Intent and Voluntary Termination

• Moralde's application for retirement benefits was viewed as a voluntary termination of his employment.
• His actions were seen as an attempt to evade a potential guilty verdict and dishonorable dismissal.
• The Court emphasized that reinstating someone who voluntarily left their position is impractical and unjust.

Distinction Between Retirement and Separation Benefits

• The Court of Appeals noted the differences between retirement and separation benefits under Republic Act No. 8291.
• Retirement benefits require specific age and service conditions, while separation benefits are available under different circumstances.
• Moralde's age and service length at the time of his application indicated he was not eligible for retirement benefits.

Implications of Moralde's Actions

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