Case Summary (G.R. No. L-37446)
Administrative Complaint
The administrative complaint was initiated by Quires based on several allegations against Labastida, including her failure to submit a revised Comprehensive Land Use Program (CLUP) as directed by Mayor Napoleon Cuaton. Quires alleged that Labastida's neglect led to the filing of the complaint. Additionally, claims were made about Labastida's disrespectful conduct during legislative inquiries and her refusal to participate in mandatory training programs, culminating in perceived misconduct on social media.
Initial Findings and Dismissal
On June 18, 2015, the Disciplining Authority dismissed Labastida from service, concluding that she was guilty of the charges outlined. Labastida appealed her dismissal to the Civil Service Commission (CSC), which found procedural faults in her initial prosecution, noting due process violations for lack of a formal charge and failure to provide her a chance to respond. Consequently, the CSC granted Labastida's appeal and reinstated her on March 14, 2016.
Re-filing of Complaint
The administrative complaint was re-filed against Labastida on May 2, 2016, leading to another resolution of guilt by the Disciplining Authority on June 10, 2016, which resulted in Labastida's dismissal again. Following this, the decision was sent via registered mail, with a notable annotation of refusal on June 14, 2016, by an unidentified recipient.
CSC Appeal and Dismissal
Labastida filed an appeal with the CSC, asserting that she only became aware of the June 10, 2016, decision on March 8, 2017. After evaluating the timelines, the CSC concluded that Labastida's appeal was submitted beyond the allowable period of 15 days and subsequently dismissed her appeal on December 19, 2017, affirming the June 10, 2016 decision.
Court of Appeals Ruling
Labastida subsequently sought relief from the Court of Appeals (CA), which upheld the CSC's ruling on April 10, 2019, relying on the presumption that the registered mail had been duly delivered. The CA opined that Labastida's appeal was untimely, considering the registry return receipt as adequate evidence of proper service.
Issues Raised by Labastida
Labastida's arguments centered around the claim that the presumption of proper service through registered mail should not apply, given evidence of non-receipt and alleged procedural irregularities regarding the service of the June 10 decision. She called into question the sufficiency of the evidence presented by Quires to affirm that the letter was mailed and received correctly.
Supreme Court Review and Rulings
Upon review, the Supreme Court recognized the merit of Labastida's claims, stating that the CA erroneously upheld the presumption of service. The Court concluded that Quires bore the burden of proving that the decision was properly served, a burden she did not satisfy.
Burden of Proof and Due Process
The Court reiterated the significance of the registry receipt being accompanied by a postmaster's affidavit to establish service of documents via registered mail. The absence of such an affi
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Background and Facts of the Case
- The case arose from an administrative complaint filed by Monina C. Quires against Victoria M. Labastida, who was then the Municipal Planning and Development Officer (MPDO) of Saint Bernard, Southern Leyte.
- Quires accused Labastida of gross neglect of duty and conduct prejudicial to the best interest of the service relating to her failure to timely and properly revise the Comprehensive Land Use Program (CLUP) as directed by the Municipal Mayor.
- Labastida failed to submit the revised CLUP by the extended deadline, submitted a deficient CLUP in February 2014, and did not attend a mandatory training seminar.
- Additional allegations included refusal to cooperate in an inquiry in aid of legislation, posting embarrassing social media comments, and dishonesty in her performance evaluation report.
- The Office of the Municipal Mayor found Labastida liable and dismissed her in June 2015, with penalties including dismissal, forfeiture of pension benefits, and disqualification from public office.
Proceedings and Decisions in the Administrative Tribunals
- Labastida appealed to the Civil Service Commission (CSC), which in 2016 overturned the dismissal due to violations of due process — notably the absence of formal charges and lack of opportunity to file a comment.
- The complaint was dismissed without prejudice, and Labastida was reinstated with backwages.
- The complaint was re-filed on May 2, 2016; the Disciplining Authority reaffirmed the dismissal penalty on June 10, 2016, citing failure to attend preliminary investigation and submit counter-affidavit.
- The copy of the June 10, 2016 Decision was sent via registered mail, but the registry return receipt was annotated "refused to accept 06-14-16," indicating non-acceptance by Labastida.
- Labastida filed a Notice of Appeal on March 16, 2017, claiming she only received the decision on March 8, 2017.
Rulings of the Civil Service Commission and Court of Appeals
- CSC dismissed Labastida's appeal as filed out of time, holding that the reckoning period began on June 14, 2016, the date on the registry return receipt.
- Labastida's motion for reconsideration was denied by the CSC.
- The Court of Appeals (CA) affirmed CSC's decision, applying the presumption of regularity in postal service and holding that the registry receipt constituted substantial evidence of service.
- The CA declared the decision final and executory due to the late appeal.
- Labastida's motion for reconsideration before the CA was likewise denied.
Issues on Appeal Before the Supreme Court
- The central issue was whether the CA erred in ruling that the appeal was filed out of time.
- Labastida contended the reckoning period should start from the actual receipt on March 8, 2017.
- She argued that the presumption of regularity of postal service was rebutted by evidence to the contrary, in