Case Summary (G.R. No. L-23893)
Background and Reassignment
Remedios Pastor was appointed as the Budget Officer of Pasig on May 1, 1986, and her appointment was confirmed on July 17, 1987. In July 1992, she was reassigned to the Office of the Municipal Administrator by the newly elected Mayor Vicente Eusebio due to adverse reports regarding her issuance of Advice of Allotments without sufficient cash collections. This memorandum directed her to temporarily report to the Municipal Administrator while a thorough investigation was to take place.
Allegations and Complaints
By 1995, after three years without any formal charges against her, Pastor sought reinstatement, but instead of being restored to her original position, she was reassigned again. On October 20, 1995, she filed a complaint with the CSC, alleging that her reassignment and removal from the payroll constituted oppression and abuse of authority, hence infringing on her civil service rights. She requested reinstatement and a prohibition against the mayor from designating another officer to her position.
Civil Service Commission's Initial Resolution
The CSC found merit in Pastor's complaint, ordering her reinstatement as Budget Officer in its Resolution No. 96-1190 dated February 5, 1996. The CSC reasoned that while her initial reassignment might have been warranted by exigent circumstances, the prolonged assignment of over three years lacked sufficient justification.
Subsequent Developments and Further CSC Resolutions
After the CSC's order, the City of Pasig assigned Pastor as head of the Pasig City Hall Annex; however, Pastor contended this position was fabricated, lacking formal creation or equivalent responsibilities associated with her previous role. The CSC reiterated its stance in subsequent resolutions, including Resolution No. 97-2845 on May 20, 1997, affirming Pastor's reassignment was non-compliant and instructing the city government to cease further reassignments.
Appeal to the Court of Appeals
In response to the CSC's resolutions, Mayor Eusebio filed a petition for certiorari in the Court of Appeals, which ruled in favor of the City, stating the reassignment was a valid exercise of the City's powers. The appellate court concluded that the status and salary of Pastor remained unchanged, validating the reassignments to both the Municipal Administrator's office and the City Hall Annex.
Petitioner's Contentions
Pastor challenged the Court of Appeals’ ruling, claiming it represented a grave abuse of discretion. She argued that the City of Pasig, not being the adversely affected party, lacked standing to appeal. Additionally, she sought reinstatement to her original position, asserting the City had failed to comply with the CSC’s directives.
Supreme Court's Ruling
The Supreme Court favored Pastor and granted her petition. It held that the City of Pasig's petition for certiorari should have be
...continue readingCase Syllabus (G.R. No. L-23893)
Background of the Case
- Petitioner Remedios Pastor served as the Budget Officer for the Municipality of Pasig, later the City of Pasig, appointed on May 1, 1986, and confirmed by the Department of Budget and Management on July 17, 1987.
- In 1992, Mayor Vicente P. Eusebio reassigned Pastor to the Office of the Municipal Administrator due to an adverse report regarding the issuance of Advice of Allotments without sufficient cash collections, pending an investigation.
- By 1995, with no case filed against her and after three years of reassignment, Pastor requested reinstatement to her original position but was instead detailed to another unit.
- Following her complaint, the Civil Service Commission (CSC) ordered her reinstatement as Budget Officer; however, this decision was later overturned by the Court of Appeals.
Procedural History
- Pastor filed a complaint with the CSC in October 1995, alleging violations of civil service laws due to her prolonged reassignment and the deletion of her name from the payroll.
- The CSC issued Resolution No. 96-1190 on February 5, 1996, ordering her reinstatement, citing the lack of