Case Summary (G.R. No. 88167)
Jurisdiction of the Merit Systems Board
The MSB, established under Presidential Decree No. 1409, was empowered to hear administrative cases involving civil service employees. The University of the Philippines contested the jurisdiction of the MSB, relying on the precedent set in University of the Philippines vs. Court of Appeals, which asserted that disciplinary matters for UP employees fall under the jurisdiction of UP itself. The MSB rejected this motion, ultimately exonerating Pamplina and ordering his reinstatement in a decision dated July 5, 1985.
Appeals Process and Denial of Reconsideration
Following the MSB's decision, UP filed for reconsideration, which was denied. The Civil Service Commission (CSC) subsequently issued Resolution No. 87-428 on November 4, 1987, upholding the MSB's ruling. UP attempted a second reconsideration, which was denied as only one request for reconsideration was permitted under Section 39(b) of PD 807. Pamplina's Manifestation and Motion for Execution of Judgment was then granted by the Commission on November 7, 1988, although UP claimed the resolutions had not yet become final.
Writ of Mandamus and RTC Decision
Pamplina sought a writ of mandamus on November 11, 1988, to compel his reinstatement, which was granted by Judge Teodoro P. Regino on April 27, 1989. The court ordered UP to reinstate Pamplina with back wages from the date of his dismissal and for the duration of his preventive suspension.
Petition for Certiorari by UP
On June 19, 1989, UP filed a petition for certiorari seeking to annul the RTC's decision and the CSC orders that mandated Pamplina’s reinstatement. UP argued it had institutional autonomy under its charter, Act 1870, asserting that disciplinary actions against its employees fell solely under the jurisdiction of the Board of Regents.
Applicability of Civil Service Law
The Civil Service Law, embodied in PD 807, grants the CSC appellate authority over administrative disciplinary cases involving civil service members. Under both the 1972 Constitution and the 1987 Constitution, UP was deemed part of the civil service, with the latter refining this to include only government-owned or controlled corporations with original charters. UP qualified under this definition, thereby necessitating adherence to the Civil Service Commission's rules.
Procedural Timeliness and Finality of Orders
The petitioners were deemed to have not adhered to the procedural requirements for filing, as they received notice of the Commission’s resolution on April 22, 1988, and failed to file their certiorari petition within the stipulated thirty-day period. Their second motion for reconsideration, which was
...continue readingCase Syllabus (G.R. No. 88167)
Case Overview
- The case involves the dismissal of Angel Pamplina, a mimeograph operator at the University of the Philippines (UP) School of Economics, on June 22, 1982, due to allegations of dishonesty and grave misconduct for leaking final examination questions in Economics 106.
- Following his dismissal, Pamplina filed an appeal which was denied by the UP Board of Regents, leading him to seek relief from the Merit Systems Board (MSB) established under Presidential Decree No. 1409.
Jurisdictional Issues
- UP challenged the jurisdiction of the MSB to hear the case, arguing that disciplinary matters involving UP employees fall under the authority of UP and its Board of Regents.
- The MSB denied UP's motion to dismiss for lack of jurisdiction and ultimately ruled in favor of Pamplina on July 5, 1985, exonerating him and ordering reinstatement with back wages.
Procedural History
- After the MSB's decision, UP sought reconsideration, which was denied on January 10, 1986. UP then appealed to the Civil Service Commission (CSC), which upheld the MSB's decision on November 4, 1987.
- A second motion for reconsideration was filed by UP on June 10, 1988, but this was denied