Case Summary (G.R. No. L-46218)
Factual Background
On November 25, 1971, the Provincial Board passed Resolution No. 204, resulting in the abolition of Madrigal’s position as a permanent construction capataz due to the province's financial limitations and the determination that his position was non-essential. Following the abolition, Madrigal appealed to the Civil Service Commission on April 22, 1972. His appeal was ruled in his favor; on January 7, 1974, the Commission deemed his dismissal illegal, prompting him to pursue reinstatement and back salary claims thereafter.
Procedural History
Madrigal's requests for reinstatement were met with resistance; the Provincial Board denied his request on August 18, 1975, asserting that his position no longer existed. Consequently, he filed a petition for mandamus and damages in the Marinduque Court of First Instance on December 15, 1975. The trial court dismissed this petition on March 16, 1976, on the grounds of laches, concluding that the four-year delay in filing the case barred his claim.
Grounds for Dismissal
In its judgment, the trial court emphasized the one-year limitation period established in previous jurisprudence for filing actions for reinstatement in civil service. The court stated that despite potentially having a good cause of action, the time elapsed from his dismissal to filing the petition—exceeding the one-year period—qualified as abandonment of his right to reinstatement. The trial court's ruling was also buttressed by citations from various cases highlighting the need for timely actions concerning public office claims.
Arguments on Appeal
Madrigal contested the trial court's dismissal, asserting that the one-year period limitations applicable to quo warranto actions did not extend to mandamus petitions and that the exhaustion of administrative remedies should result in a waiver of the prescriptive period. The respondents countered that established jurisprudence necessitated filing actions for reinstatement within one year following dismissal, and the pendency of administrative remedies did not halt this timeline.
Legal Principles and Jurisprudence
The ruling cited several relevant cases affirming that both mandamus and quo warranto actions related to public office reinstatement must be initiated
...continue readingCase Syllabus (G.R. No. L-46218)
Case Citation
- 269 Phil. 20 FIRST DIVISION [ G.R. No. L-46218. October 23, 1990 ]
Parties Involved
- Petitioner-Appellant: Joventino Madrigal
- Respondents-Appellees:
- Prov. Gov. Aristeo M. Lecaroz
- Vice-Governor Celso Zoleta, Jr.
- Provincial Board Members Domingo Riego and Marcial Principe
- Prov. Engr. Enrique M. Isidro
- Abraham T. Taduran
- Province of Marinduque
Certification
- The case was certified to the Supreme Court by the Court of Appeals due to the presentation of pure questions of law.
Issues Presented
- The case concerns the prescriptive period for filing a petition for mandamus for reinstatement to a government position and the associated claims for back salaries and damages.
Antecedent Facts
- On November 25, 1971, the position of Joventino Madrigal as a permanent construction capataz was abolished due to poor financial conditions and claims that his position was not essential.
- Madrigal appealed to the Civil Service Commission (CSC) on April 22, 1972.
- The CSC declared the removal illegal on January 7, 1974, and subsequently denied the motion for reconsideration on February 10, 1975.
- On August 4, 1975, Madrigal requested reinstatement, which was denied on August 18, 1975, by the Provincial Board, citing the non-existence of his former position.
- Madrigal filed a petition for mandamu