Case Summary (G.R. No. 112513)
Background of the Case
The petitioner, Edgar R. Del Castillo, an employee of the Professional Regulation Commission (PRC), was placed under preventive suspension on August 1, 1990, based on allegations of grave misconduct and conduct prejudicial to the best interest of the service. Following an investigation, he was found guilty of these charges and subsequently dismissed, forfeiting all benefits. Del Castillo appealed this decision to the Merit Systems Protection Board (MSPB), which ultimately exonerated him. However, an appeal by the PRC led the Civil Service Commission (CSC) to affirm his dismissal, stating he had committed grave misconduct. A motion for reconsideration by Del Castillo was denied.
Supreme Court Ruling
In an En Banc Decision issued on February 14, 1995, the Supreme Court granted Del Castillo’s petition for certiorari, concluding that the CSC had committed grave abuse of discretion by entertaining the PRC's appeal. The Court's ruling reversed the CSC's resolutions and reinstated the MSPB's decision, exonerating Del Castillo from the charged misconduct. However, the decision was silent on the issue of back wages.
Request for Clarification
Following the Supreme Court's ruling, Del Castillo requested payment of back wages and benefits from PRC Chairman Hermogenes Pobre, in addition to his reinstatement, which was executed on July 17, 1995. However, his request for back wages was denied by Chairman Pobre in a letter dated November 28, 1995, citing the lack of legal basis for such payment due to the Supreme Court decision's silence on the matter.
Motion for Clarificatory Relief
In response to this denial, Del Castillo filed a motion for clarificatory relief with the Supreme Court. The CSC submitted comments noting that the primary issue to be clarified was whether Del Castillo was entitled to back wages and benefits from the date of his preventive suspension until his reinstatement. The CSC acknowledged that the ruling did not object to Del Castillo's motion and left the resolution to the Court's discretion.
Argument by the Solicitor General
The Solicitor General supported Del Castillo's claim for back wages, referencing previous jurisprudence that established that public officials reinstated after illegal dismissal are entitled to back salaries. The Solicitor General cited key cases confirming that those wrongfully dismissed are deemed to have never left their positions and thereby retain the rights accorded to them, including back
...continue readingCase Syllabus (G.R. No. 112513)
Background of the Case
- Petitioner Edgar R. Del Castillo was an employee of the Professional Regulation Commission (PRC).
- On August 1, 1990, he was placed under preventive suspension by the PRC due to allegations of "grave misconduct" and "conduct prejudicial to the best interest of the service."
- Following an investigation, Del Castillo was found guilty of the charges and subsequently dismissed from service, with the forfeiture of all benefits.
Appeal Process
- Del Castillo appealed his dismissal to the Merit Systems Protection Board (MSPB), which exonerated him of the charges against him.
- The PRC contested this decision, leading to a review by the Civil Service Commission (CSC).
- On appeal, the CSC upheld the PRC's decision, finding Del Castillo guilty of grave misconduct and imposing a penalty of dismissal.
- Del Castillo's motion for reconsideration was denied by the CSC.
Supreme Court Involvement
- Del Castillo filed a petition for certiorari under Rule 65 of the Rules of Court, alleging that the CSC committed grave abuse of discretion by entertaining the PRC's appeal.
- On February 14, 1995, the Supreme Court granted the petition, reversing the CSC's decision and reinstating the MSPB's ruling.
Ruling Details
- The Supreme Court's decision reinstated Del Castillo to his former position but