Festejo v. Pornillos
REITERATIONFacts
The Antecedents: Chief of Police Adriano Festejo of Nabua, Camarines Sur, was charged with "laxity and negligence in the custody of prisoners" for allowing a detention prisoner to escape. On April 1, 1950, a complaint was filed by Captain Ignacio Elegado, P.C. Commanding Officer. Procedural History: On April 21, 1950, the Municipal Mayor suspended Festejo. The Municipal Council created an "Integrity Board" to investigate. Festejo's counsel questioned the Board's jurisdiction, and upon being overruled, Festejo refused to participate. The Board found Festejo guilty and exonerated Sergeant Regino Sernal. On October 9, 1950, the Mayor notified Festejo of his complete separation from the service, confirming the Board's decision. Festejo's counsel filed a notice of appeal and motion to declare proceedings void ab initio with the Commissioner of Civil Service on October 21, 1950, which was received on October 25, 1950. Festejo also sought reinstatement through higher executive authorities without success. The Petition: Festejo filed a petition for a writ of mandamus in the Court of First Instance (CFI) of Camarines Sur, seeking reinstatement and back salaries, and damages. The CFI dismissed the appeal to the Commissioner of Civil Service, ruling that it was filed out of time, as service of notice by ordinary mail was complete on October 26, 1950, which was beyond the 15-day period from Festejo's receipt of the decision on October 10, 1950. The appellant argued that the Integrity Board's decision was void ab initio under Republic Act No. 557, as the investigation should have been conducted by the Municipal Council, not a committee, and thus, there was no final decision from which to appeal.
Issue(s)
Whether the investigation and decision of the "Integrity Board" were valid under Republic Act No. 557. Whether the appeal to the Commissioner of Civil Service was filed out of time. Whether the appellant is entitled to reinstatement and back salaries via a writ of mandamus.
Ruling
The Supreme Court reversed the decision of the Court of First Instance. It ordered the issuance of a writ of mandamus to reinstate appellant Adriano Festejo as Chief of Police of Nabua. No costs.
Ratio Decidendi
On Issue 1: The Supreme Court held that the investigation and decision of the "Integrity Board" were invalid and void ab initio. Republic Act No. 557, enacted on June 17, 1950, expressly requires that charges against members of the municipal police be investigated by the municipal council in a public hearing. The Act does not authorize the council to delegate this investigative power to a committee. Therefore, the "Integrity Board," being a mere committee, lacked the legal authority to conduct the investigation and render a decision. This procedural defect rendered the entire proceedings null and void, irrespective of the merits of the charge. On Issue 2: The Supreme Court ruled that the argument that the appeal was filed out of time was untenable. The Court reasoned that since the decision of the "Integrity Board" was void for want of power and authority, there was no valid decision from which an appeal could be taken. Jurisdiction is a pure question of law, and when an administrative body acts without jurisdiction, its decisions are nullities, and the aggrieved party is not bound by procedural timelines for appeals from valid decisions. Thus, Festejo was not precluded from seeking judicial remedy. On Issue 3: The Supreme Court held that Festejo was entitled to reinstatement and back salaries. Because the investigation and decision were void, there was no final decision on the case. Section 3 of Republic Act No. 557 mandates that if a case is not decided finally within 60 days of suspension, the accused shall be ipso facto reinstated. Compliance with this provision is enforcible by mandamus. The Court also found that Festejo had attempted to exhaust administrative remedies by petitioning the President and the Secretary of the Interior, but these efforts were unsuccessful.
Main Doctrine
The Supreme Court held that under Republic Act No. 557, the investigation of charges against a member of the municipal police must be conducted by the municipal council itself in a public hearing, and not by a committee or board created by the council. Consequently, any investigation and decision rendered by such a committee, like the 'Integrity Board' in this case, are null and void for want of jurisdiction. Furthermore, if a suspended official's case is not decided within the 60-day period provided by law, they are automatically reinstated.