G.R. No. L-17652 - Grande vs. Court of Appeals

Case Summary (G.R. No. L-17652)

Factual Background and Administrative Proceedings

Retired career diplomat Rosalina V. Tirona was appointed PLP President by Mayor Eusebio in 2008 for a four-year term ending January 31, 2012, with CSC approval. Upon Eusebio’s re-election in 2010, he requested all Pasig City office chiefs, including Tirona, to submit courtesy resignations. Tirona refused, prompting Eusebio to terminate her appointment on July 19, 2010, citing her attainment of compulsory retirement age. Tirona challenged her dismissal before the CSC. The CSC ruled on September 23, 2010, that Tirona was illegally dismissed and ordered her reinstatement. Eusebio and the PLP Board of Regents filed motions for reconsideration, which were denied. Upon appeal to the Court of Appeals, no injunctive relief was issued to stop Tirona’s reinstatement, yet Eusebio did not comply with the CSC order.

Contempt Charges and Fines Imposed by the CSC

Due to Eusebio’s non-compliance, the CSC motu proprio filed a charge of indirect contempt on June 21, 2011. Eusebio’s defense was that his appeal stayed the reinstatement order, and that Tirona did not move for its enforcement. Nevertheless, the CSC found Eusebio guilty of indirect contempt and imposed a fine of P1,000 per day from December 13, 2010 (date of denial of reconsideration) until January 31, 2012 (expiration of Tirona’s term), totaling P416,000. The CSC ordered that this fine be deducted from Eusebio’s salary and paid to the Commission. Eusebio’s motion for reconsideration was denied.

Proceedings Before the Court of Appeals

Eusebio filed a petition for review before the Court of Appeals challenging the contempt finding and fine. While the Court affirmed Eusebio’s liability for indirect contempt, it significantly reduced the fine from P416,000 to P30,000. The Court reasoned that the CSC’s Revised Rules on Contempt, which imposed the P1,000 daily fine, had no enabling law explicitly authorizing that amount. It viewed the penalty imposed as confiscatory and unreasonable, emphasizing that administrative agencies must act within their delegated legislative authority and adopt reasonable rules. Instead, the Court fixed the maximum fine at P30,000, aligning it with Section 7, Rule 71 of the Rules of Court on contempt fines.

Petition for Review and Constitutional Authority of CSC

The Office of the Solicitor General (OSG) petitioned to reverse the Court of Appeals' reduction, citing Section 6, Article IX-A of the 1987 Constitution, which authorizes the CSC to promulgate its own rules on pleadings and practice in its offices, and Section 12(2), Title I, Book V of the Administrative Code of 1987 (EO 292), which empowers the CSC to prescribe and enforce rules to carry out the Civil Service Law. The OSG maintained that the CSC’s Revised Rules on Contempt, including the P1,000 per day fine, were valid exercises of its constitutional and statutory powers, not prohibited by the absence of specific penalty provisions in EO 292 or the Constitution.

Eusebio’s Position on Good Faith and Applicability of the Rules

Eusebio contended that his failure to reinstate Tirona was made in good faith, arguing he lacked full authority to implement the reinstatement, and that the Court of Appeals was correct to invalidate Section 4 of the CSC Revised Rules on Contempt for exceeding the scope of EO 292. He further noted that Tirona herself initiated a contempt proceeding against him, evidencing the ongoing dispute over compliance.

Legal Issue: Finality and Validity of the Fine Imposed

The Supreme Court first clarified that Eusebio’s guilt for indirect contempt had long been final and unappealable following the closure of his second petition for review, thus only the propriety of the fine’s reduction remained at issue. It then analyzed the constitutional and statutory grant of authority to the CSC to promulgate its own procedural and contempt rules and enforce their penalties.

Supreme Court’s Analysis on the Contempt Power of the CSC

The Court ruled that under Section 6, Article IX-A of the 1987 Constitution, the CSC may adopt its own rules on pleadings and practice that do not modify substantive rights. EO 292’s Section 12(2) further explicitly authorizes the CSC to prescribe and enforce rules to implement civil service laws. Consequently, the CSC Revised Rules on Contempt are within the CSC’s delegated power, and the Court recognized the legitimacy of those rules and their penalties.

The Court distinguished Section 16(2)(d) of EO 292, granting the Merit System Protection Board power to punish contempt according to Rules of Court procedures and penalties, as providing only a suppletory role to the Rules of Court vis-à-vis the CSC’s own rules. The Rules of Court must defer to the CSC’s rules concerning contempt committed against the Commission.

Validity and Discretionary Nature of the Fine Penalty

The Court upheld Section 4 of the CSC Revised Rules on Contempt, which allows imposition of a P1,000 per day fine for every day of disobedience or non-compliance with a final CSC order, and potential liability for consequential damages. The term “may” in the provision gives the CSC discretion to impose lesser

Case Syllabus (G.R. No. L-17652)

Case Background and Parties Involved

Two consolidated cases: G.R. No. 223623 and G.R. No. 223644 involving Roberto C. Eusebio and the Civil Service Commission (CSC).
Roberto C. Eusebio served as Mayor of Pasig City and was also Chairman of the Board of the Pamantasan ng Lungsod ng Pasig (PLP).
Rosalina V. Tirona, retired career diplomat, was appointed PLP President for a fixed term (2008 to 2012), appointment approved by the CSC.
Dispute arose when Mayor Eusebio terminated Tirona’s appointment citing compulsory retirement at age 70.
Tirona challenged her termination before the CSC, which ruled her dismissal illegal and ordered her reinstatement.
Eusebio defied the CSC order, which led to charges of indirect contempt against him by the CSC.

Factual Antecedents of the Case

Tirona was appointed PLP President on February 1, 2008, with a term until January 31, 2012.
Upon re-election, Mayor Eusebio called for courtesy resignations from city officials including Tirona on June 7, 2010; Tirona refused.
On July 19, 2010, Eusebio terminated Tirona's appointment citing compulsory retirement age.
CSC, on September 23, 2010, ruled the dismissal illegal and ordered reinstatement.
Eusebio and PLP Board of Regents filed motions for reconsideration, both denied.
Despite no injunctive relief to stay the reinstatement order, Eusebio did not comply.
CSC found Eusebio guilty of indirect contempt for failure to implement its final and executory decision.

Civil Service Commission's Decision and Penalty

By Decision No. 12-0843 dated November 26, 2012, the CSC imposed a fine of P1,000 per day for 416 days on Eusebio, totaling P416,000.
The fine counted from December 13, 2010, when the motion for reconsideration was denied, until Tirona’s term expired on January 31, 2012.
The penalty was imposed pursuant to Section 4 of CSC’s Revised Rules on Contempt (Memorandum Circular No. 42, s. 1990, amended by CSC Resolution No. 071245).
The rules establish that each day of defiance to a final CSC order constitutes indirect contempt punishable by a fine.
Eusebio’s salary was directed to be deducted for the fine amount.
Eusebio’s motion for reconsideration of the penalty was denied.

Proceedings Before the Court of Appeals

Eusebio filed a petition for review before the Court of Appeals (CA-G.R. SP No. 129526) assailing the penalties for indirect contempt.
The Court of Appeals affirmed Eusebio's indirect contempt liability but drastically reduced the P416,000 fine to P30,000.
The CA reasoned that the CSC’s fine of P1,000 per day lacked specific statutory basis and was unreasonable and confiscatory.
The CA held that the CSC exceeded its delegated rule-making authority by extending the penalty beyond what EO 292 prescribes.
The CA imposed the fine based on Section 7, Rule 71 of the Rules of Court, which caps contempt fines at P30,000.
Both parties moved for reconsideration, which the CA denied.

Issues Presented to the Supreme Court

The primary issue: whether the Court of Appeals erred in reducing the fine i