G.R. No. 239011 - Civil Service Commission vs. Rasuman

Case Summary (G.R. No. 239011)

Facts of the Case

Respondent Pacol Disumimba Rasuman filed a verified petition before the RTC of Lanao del Sur seeking correction of his birthdate from February 12, 1952 to February 12, 1956, impleading the Local Civil Registrar of Marantao as respondent. The RTC set the case for hearing and mandated publication of notice. Respondent later amended his petition to also implead the Bureau of Customs (BOC), where he was employed, for the correction of his official records. On July 23, 2015, the RTC granted the petition, directing the Local Civil Registrar to annotate and forward the corrected birth certificate, and the BOC to update employment records accordingly. The decision became final and executory on October 8, 2015.

Proceedings Before the Civil Service Commission

Respondent requested the CSC-NCR to correct his date of birth in his service records; however, CSC-NCR denied the request on June 27, 2016. It reasoned that while the corrected birth certificate supported the claim, employment and school records contradicted the change, casting doubt on the claimed birthdate. Upon petition for review before the CSC Proper, the CSC affirmed the denial on January 13, 2017, holding it was not bound by the RTC decision because it was not impleaded as a party despite being an indispensable party, citing Police Senior Superintendent Macawadib v. PNP.

Decision of the Court of Appeals

Respondent filed a petition for review with the CA, which on October 25, 2017 granted the petition, reversed and set aside the CSC decisions, and directed the CSC to comply with the RTC decision correcting respondent’s birthdate. The CA later denied petitioner CSC's motion for reconsideration on April 26, 2018.

Issues on Appeal to the Supreme Court

The Civil Service Commission questioned the CA's ruling that CSC erred in denying the correction of respondent's service records. The central issue was whether the CSC, as an indispensable party, was properly bound by the RTC decision despite not being impleaded nor personally notified in the petition for correction of birthdate.

Jurisdiction and Nature of Petition for Correction of Entry

The Court emphasized that correction of entries in the civil registry is a proceeding in rem, governed by Rule 108 of the Rules of Court, which requires that the civil registrar and all persons claiming an interest affected by the correction be made parties to the case. Notice and publication are mandated to satisfy due process requirements. The Court underscored that while jurisdiction over the res (the thing itself) suffices for in rem actions, due process requires personal notice to interested parties to afford them an opportunity to protect their interests.

Indispensability of the Civil Service Commission

The Supreme Court reiterated its prior ruling in Police Senior Superintendent Macawadib v. PNP, which held the CSC is an indispensable party in petitions correcting entries affecting government employees' service records. As the central personnel agency maintaining official civil service records pursuant to Executive Order No. 292, CSC must be impleaded to protect its interest and ensure its records' integrity. Failure to implead such indispensable parties renders any judgment ineffective and void as to such parties.

Application to the Present Case

In this case, while the respondent impleaded the BOC in his amended petition, he did not implead the CSC, despite CSC’s clear and substantial interest in correcting employment records affected by the birthdate correction. The Court found that the CSC was not notified or given an opportunity to be heard in the RTC proceeding and was not ordered by the RTC to effect any correction. Accordingly, the CSC was not bound by the RTC decision in this regard and acted properly in denying the correction request in its records.

Distinction from Civil Service Commission v. Magoyag

The Court distinguished this case from Civil Service Commission

Case Syllabus (G.R. No. 239011)

Background and Procedural History

On April 16, 2014, Pacol Disumimba Rasuman, Senior Executive Assistant of the Bureau of Customs (BOC), filed a verified petition before the Regional Trial Court (RTC) of Lanao del Sur for correction of his date of birth from February 12, 1952 to February 12, 1956, impleading the Local Civil Registrar of Marantao, Lanao del Sur as respondent.
The RTC set the case for hearing, directed publication of the Order in newspapers of general circulation, and required furnishing copies to the Local Civil Registrar, the Office of the Solicitor General, and the Civil Registrar General, which were complied with by the petitioner.
Rasuman amended his petition to implead the BOC to effect correction in his employment records.
On July 23, 2015, the RTC granted the petition correcting the birthdate, ordering the Local Civil Registrar and BOC to make the necessary annotations and corrections in their records.
The RTC Decision became final and executory on October 8, 2015.
On January 21, 2016, Rasuman filed a request with the Civil Service Commission-National Capital Region (CSC-NCR) to correct his date of birth in service records.
CSC-NCR required submission of supporting documents; Rasuman complied submitting birth certificate, affidavits, and employment and school records.
Despite the submitted evidence, CSC-NCR denied the request on June 27, 2016 by Resolution No. 1601236, citing discrepancies such as school attendance dates incompatible with the birthdate claimed.
Rasuman filed a petition for review with the CSC Proper, which on January 13, 2017 dismissed the petition, holding that CSC was not bound by the RTC decision as it was not impleaded and an indispensable party.
The CSC also denied the motion for reconsideration on May 8, 2017.
Rasuman then filed a petition for review with the Court of Appeals (CA), which in a Decision dated October 25, 2017, granted the petition, reversed the CSC decisions, and directed CSC to comply with the RTC ruling.
CSC’s motion for reconsideration was denied by the CA on April 26, 2018.
CSC filed a petition for review on certiorari before the Supreme Court (SC), alleging reversible error by the CA.

Issues on Jurisdiction and Necessity of Impleading the Civil Service Commission

The core legal issue revolved around whether the CSC, as a government agency maintaining records of civil servants, must be impleaded in petitions for correction of civil registry entries affecting employment service records.
The petition involved correction of an entry in the civil registry and its effects on government employment records.
The CSC contended it is an indispensable party under Rule 108, Section 3 of the Rules of Court requiring all persons who have or claim interest to be parties before any correction of civil registry entries can affect their rights or interests.
The Court examined the nature of actions in rem regarding correction of registry entries, emphasizing that while these are directed to the “thing” (registry), jurisdiction over affected parties is still constitutionally required to guarantee due process.
Jurisprudence including De Pedro v. Romasan and Police Senior Superintendent Macawadib v. PNP Directorate emphasized that agencies whose records will be substantially altered by correction in civil status are indispensable parties and must be impleaded to uphold fairness and legal effectivity of the judgment.
Since CSC keeps and maintains official personnel records, correction of birthdate that affects retirement and tenure rights directly impacts its interests and records.
The CSC should have been impleaded and given personal notice in the RTC proceedings before any changes could affect its records and interests;