Case Summary (G.R. No. 248852)
Factual Antecedents
On September 28, 1999, Maaliw lodged a complaint against Longasa, which remained unresolved for more than 14 years until the CSC-National Capital Region (CSC-NCR) issued a decision on June 16, 2014, dismissing the complaint for insufficient formal grounds. The delay prompted Maaliw to subsequently file a complaint against Fernandez and Director Lydia Castillo for neglect of duty. Both Fernandez and Castillo attributed the delay to their not having been in office when the complaint was filed and argued that the backlog of cases at CSC-NCR was a systemic issue beyond their control. The CSC dismissed Maaliw's complaint against Fernandez and Castillo, which led to Maaliw filing a petition for review at the CA.
Court of Appeals Decision
On January 14, 2019, the CA reversed the CSC’s decision, finding Fernandez and Castillo guilty of simple neglect of duty and imposing a fine equivalent to three months’ salary instead of suspension. The CA criticized Fernandez for delaying the resolution of the complaint and rejected her defense concerning insufficient manpower at the CSC-NCR. After Fernandez’s motion for reconsideration was denied, she filed a petition with the Supreme Court, citing three erroneous findings from the CA.
Legal Issues Raised by Petitioner
Fernandez argued that:
- The CA improperly accepted Maaliw's appeal against the CSC’s decision, which she believed was final and not subject to review by an external party such as Maaliw.
- She was denied due process as there was no formal charge against her prior to the finding of neglect of duty.
- The CA wrongly attributive the delay in resolving Maaliw's complaint to her actions, claiming her rapid response time on Maaliw's initial complaint disproved claims of neglect.
Arguments of the Respondent
Maaliw contended that the petition should be dismissed for raising factual questions, asserting that Fernandez had the chance to defend herself and that the CA's actions were within its jurisdiction to grant the appeal. He maintained that Fernandez's alleged use of workload as a defense was baseless since maintaining timely caseload management is part of professional duties under Philippine law.
Court’s Ruling
The Supreme Court found Fernandez's petition meritorious, maintaining that the case involved important legal questions regarding due process. It clarified that the appeal to the CA was valid despite the CSC's dismissal order, emphasizing that Maaliw had the requisite standing to appeal as the complainant. The Court ruled that due process had
...continue readingCase Syllabus (G.R. No. 248852)
Case Background
- This case involves a Petition for Review on Certiorari filed by Atty. Riza S. Fernandez against Willie Fernando Maaliw.
- The petition challenges the Decision dated January 14, 2019, and the Resolution dated July 26, 2019, of the Court of Appeals (CA), which reversed the earlier decisions of the Civil Service Commission (CSC).
- The CSC had previously dismissed Maaliw's complaint against Fernandez and Director Lydia Castillo due to a lack of responsibility for the delay in the resolution of Maaliw's complaint.
Factual Antecedents
- Maaliw filed a complaint against Danilo A. Longasa on September 28, 1999, alleging grave misconduct and other violations, which took 14 years to resolve.
- The CSC-National Capital Region (CSC-NCR) dismissed Maaliw's complaint on June 16, 2014, for being insufficient in form.
- In response to the long delay, Maaliw filed a separate complaint against Fernandez and Dir. Castillo in November 2015 for neglect of duty.
- Fernandez and Dir. Castillo defended themselves by stating that the delay was beyond their control and that the complaint was already pending prior to their tenure.
CSC's Initial Decision
- On August 31, 2016, the CSC dismissed Maaliw's complaint against Fernandez and Castillo, acknowledging the 14-year delay but attributing it to circumstances beyond their c