Case Summary (G.R. No. 193584)
Factual Background
On September 8, 2004, Mohammad was appointed to a temporary position as PARO II due to his lack of Career Service Executive Eligibility (CSEE). A year later, he requested a change of status to permanent based on a Regional Trial Court's (RTC) previous decision concerning similar positions. His request was denied by the respondent, citing the inapplicability of the RTC decision, which was only binding on the specific parties involved. Mohammad subsequently filed a special civil action for mandamus before the RTC, claiming the issue was purely legal and thus an exception to the exhaustion of administrative remedies.
RTC Ruling
The RTC initially ruled in favor of Mohammad, ordering the respondent to approve his appointment as permanent on July 26, 2006. The RTC concluded that the respondent unlawfully neglected to approve the appointment, even in light of the governing laws and facts. Despite the respondent's motion to dismiss based on failure to exhaust administrative remedies, the RTC believed it possessed jurisdiction due to the legal nature of the questions presented.
Court of Appeals Review
The Court of Appeals (CA) later reversed the RTC's decision, asserting that the petitioner had prematurely sought judicial intervention without exhausting all administrative remedies available to him, as prescribed by sections of the Revised Uniform Rules on Administrative Cases in the Civil Service. The CA cited numerous administrative issuances and concluded that the respondent's discretion in approving appointments was not merely ministerial but required proper adherence to established procedures.
Supreme Court's Decision
The Supreme Court upheld the CA’s decision, emphasizing the importance of the doctrine of exhaustion of administrative remedies. The Court clarified that the issue raised by the petitioner was not purely legal, as it involved factual determinations regarding the qualifications for the PARO II position. The Court detailed the distinctions between this case and previous similar cases, indicating that aspects of the position's classification and qualifications created factual inquiries that fell outside the purview of mandamus.
The Court reiterated that courts should defer to administrative processes and that unless all administrative channels have be
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Overview of the Case
- The petition for review was filed by Hambre J. Mohammad against Grace Belgado-Saqueton, who served as the Director IV of the Civil Service Commission Regional Office No. XVI.
- The case arose from a decision made by the Court of Appeals (CA) dated January 27, 2010, which reversed earlier rulings by the Regional Trial Court (RTC) of Cotabato City.
- The primary issue was whether the filing of a petition for mandamus with the RTC was appropriate given the availability of an administrative remedy against the CSCRO's unfavorable decision.
- The Supreme Court affirmed the Court of Appeals' decision, emphasizing the necessity for the exhaustion of administrative remedies.
Facts of the Case
- Mohammad was appointed as Provincial Agrarian Reform Officer II (PARO II) on September 8, 2004, with a temporary status due to the lack of Career Service Executive Eligibility (CSEE).
- His appointment was renewed in 2005, and he subsequently requested a change from temporary to permanent status based on a prior RTC decision regarding similar positions.
- The request was denied by the CSCRO, citing the inapplicability of the RTC decision to his case and the ongoing review of that decision.
- Instead of appealing to the CSC proper, Mohammad filed a special civil action for mandamus in the RTC, claiming tha