Title
Civil Service Commission vs. Pobre
Case
G.R. No. 160568
Decision Date
Sep 15, 2004
A retired official claimed terminal leave pay based on cumulative government service. Jurisdiction conflict arose between CSC and COA; SC ruled both agencies must decide.

Case Summary (G.R. No. 160568)

Background on Terminal Leave Benefits

Respondent Hermogenes P. Pobre had previously received terminal leave pays totaling P365,522.60 from his first two retirement incidents. For his third retirement from the PRC, however, Pobre sought to compute his terminal leave benefits based on his highest monthly salary as PRC chairman, dating back to 1958, the start of his government service as a budget examiner. This claim is grounded in Section 13 of Commonwealth Act 186, which provides the framework for calculating retirement benefits based on aggregate years of service across multiple positions in the government.

Initial Resolutions by the CSC

Doubts regarding the legality of Pobre's claims prompted the successor chairperson of the PRC, Antonieta Fortuna-Ibe, to consult the CSC and the Commission on Audit (COA). On October 29, 2001, the CSC issued Resolution No. 01-1739, concluding that Pobre was entitled only to terminal leave benefits accrued since his appointment as PRC chairman, excluding leave credits from his previous positions. Pobre sought reconsideration, leading to the issuance of Resolution No. 02-0236 on February 19, 2002, which partially modified the prior resolution to include service as PRC associate commissioner.

Appeal to the Court of Appeals

Dissatisfied with the CSC’s resolutions, Pobre elevated the matter to the Court of Appeals, presenting two primary issues: (1) whether the CSC had jurisdiction over his claim for terminal leave benefits while it was also under consideration by the COA, and (2) whether terminal leave benefits for a retiree serving in multiple government agencies could be computed based on overall service since initial employment, similar to the provisions under Commonwealth Act 186.

Decision by the Court of Appeals

In its decision dated March 31, 2003, the Court of Appeals ruled in favor of Pobre by annulling the CSC’s resolutions and asserting that the COA had jurisdiction over disputes regarding claims for terminal leave benefits. The Court ordered the parties to await the COA's determination regarding Pobre's claim before proceeding further. This decision was premised on the conclusion that the matter of auditing funds and expenditures related to terminal leave benefits falls within the COA's exclusive sphere of authority.

Petitioner’s Arguments on Reconsideration

Following the adverse ruling, the CSC filed a motion for reconsideration which was denied on September 24, 2003. The CSC continued to assert that it had jurisdiction to determine the legality of Pobre's claim, relying on its mandate under the 1987 Administrative Code. It cited a range of powers encompassing the administration of retirement programs and oversight of benefit implementations.

Jurisdictional Authority of the COA and CSC

The Court underscored the delineated powers of both the CSC and the COA, referencing the mandates established under Article IX-D of the 1987 Constitution. The COA's responsibilities include auditing and settling all government accounts, including expenditures related to

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