Title
Mancita vs. Barcinas
Case
G.R. No. 98120
Decision Date
Dec 22, 1992
Filomena Mancita’s permanent MDC position was abolished; CSC ordered her reinstatement. RTC attempted to nullify CSC’s decision, but SC ruled RTC lacked jurisdiction, affirming CSC’s finality.
jurisdiction
review
unappealable

Case Summary (G.R. No. 98120)

Factual Background and Administrative History

Mancita was serving as MDC when the Local Government Code took effect. On 28 March 1983, Pili’s Sangguniang Bayan created the Office of the MPDC through Resolution No. 38. On 1 January 1985, Pili’s approved reorganization plan took effect. By letter dated 17 June 1985, Mayor Anastacio M. Prila informed Mancita that her position of MDC was abolished and that her services would terminate at the close of office hours on 30 June 1985. On 30 June 1985, Mayor Prila appointed private respondent Prescilla B. Nacario as MPDC effective 1 July 1985.

Mancita appealed her separation to the Merit Systems Protection Board (MSPB), which was docketed as MSPB Case No. 248. On 20 June 1989, the MSPB ruled that Mancita’s appeal was meritorious. It ordered her reinstatement to her former or equivalent position and awarded back salaries from the date of her illegal separation. The municipality sought reconsideration, but on 13 December 1989 its motion was denied.

On appeal by the municipality, the Civil Service Commission affirmed the MSPB in Resolution No. 90-657 dated 16 July 1990. After this affirmance, on 15 October 1990, Mayor Delfin N. Divinagracia, Jr., who had succeeded Mayor Prila, notified Nacario that her services as MPDC would be terminated effective 16 November 1990 to make way for Mancita’s reinstatement. On the same date, the Mayor notified Mancita that she would be reinstated to her former position effective 16 November 1990.

On motion, the Civil Service Commission issued an order dated 9 November 1990 directing the immediate implementation of the Civil Service Commission’s resolution of 16 July 1990 and the MSPB decision of 20 June 1989, including the related resolution of 13 December 1989.

RTC Petition and Issuance of Temporary Restraining Order

On 8 November 1990, private respondent Prescilla B. Nacario filed with the RTC of Pili, Branch 31, Civil Case No. P-1781, entitled “Prescilla B. Nacario vs. The Civil Service Commission, et. al.”. Nacario’s action was styled as a petition for declaratory relief and prohibition with preliminary injunction, and it named as respondents the Civil Service Commission through its Chairman Patricia A. Sto. Tomas, Mayor Delfin N. Divinagracia, Jr., the CSC Regional Director, and Mancita. The reliefs sought included a restraining order to stop implementation of the termination of Mancita and to direct Mancita’s reinstatement, and to prevent Mancita from assuming or occupying the MPDC position. Nacario also sought a preliminary and permanent injunction to declare the MSPB and Civil Service Commission resolutions void and without legal effect, invoking constitutional security of tenure.

Acting on the petition, respondent Judge issued, on the same day, a temporary restraining order and scheduled the hearing for the application for a writ of preliminary injunction on 22 November 1990.

Proceedings on the Motion to Dismiss

Mancita responded by filing an answer and a motion to dismiss. She argued that the RTC had no jurisdiction to review or pass upon a final judgment, order, or decision of the Civil Service Commission, a constitutional body. Mayor Divinagracia filed his answer and, thereafter, a manifestation stating that he adopted Mancita’s motion to dismiss as incorporated in his answer.

On 25 February 1991, respondent Judge issued an order denying the motion to dismiss. Mancita’s motion for reconsideration was likewise denied by the order dated 8 April 1991.

Issues Raised in the Petition for Certiorari

Mancita challenged the RTC’s orders as void for being issued without or in excess of jurisdiction. She invoked the principle that Civil Service Commission decisions, orders, or rulings are unappealable and subject only to the Supreme Court’s certiorari jurisdiction under the Constitution. Her position was grounded on Rule 65 of the Rules of Court and on the constitutional provision governing review of actions of the constitutional commissions.

Supreme Court’s Ruling and Disposition

The Supreme Court granted the petition. It annulled and set aside the questioned RTC orders dated 8 November 1990, 23 February 1991, and 8 April 1991, and it made the temporary restraining order previously issued by the Court permanent, with costs against the private respondent.

The Court held that the RTC had no jurisdiction over Civil Case No. P-1781 because the action sought to review a decision, order, or ruling of the Civil Service Commission. The Court relied on Lopez, Jr. vs. The Civil Service Commission, et. al. (citing Dario vs. Mison), and reiterated that no appeal lies from a Civil Service Commission decision and that the remedy of an aggrieved party was to proceed to the Supreme Court alone on certiorari under Rule 65 within the time required by the Constitution. The Court quoted the governing constitutional text, emphasizing that unless otherwise provided by the 1987 Constitution or by law, a decision, order, or ruling of a commission may be brought to the Supreme Court on certiorari by the aggrieved party within thirty days from receipt of a copy. It further stressed that the Civil Service Commission is the single arbiter of contests relating to the civil service, rendering its judgments unappealable and subject only to Supreme Court review through certiorari.

Applying this doctrine, the Court concluded that since the Civil Service Commission’s ruling was reviewable only by the Supreme Court on certiorari, the RTC of Pili, Branch 31, had no authority to entertain an action that effectively sought review of that ruling.

Legal Basis and Reasoning

The Court’s reasoning rested on the constitutional framework for review of decisions of constitutional commissions. It treated the Civil Service Commission’s determinations as final and unappealable, save for the limited review mechanism of certiorari to the Supreme Court under Rule 65, consistent with Art. IX-type constitutional provisions on the manner and timing of review of commission rulings. The RTC orders were therefore void because they were anchored on proceedings that attempted to circumvent the prescribed mode of judicial scrutiny.

The Court thus declared the RTC’s assumption of jurisdiction in Civil Case No. P-1781 as

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