Dajao v. Padilla
REITERATIONFacts
The Antecedents: Petitioner Ursula C. Dajao, a Legal Officer III (later Trial Attorney IV) in the Reparations Commission, sought to compel the respondents, members of the Reparations Commission, to revoke a resolution affecting the appointment of Atty. Cayetano Jacinto to Trial Attorney IV (Item 58, P6,000.00 per annum) and to appoint her instead. She also sought to prohibit the deletion of Roman numerals from position designations and the change of Trial Attorney II (Item 60-2, P6,000.00 per annum) to Assistant Chief Trial Attorney in the proposed budget for fiscal year 1965-1966. Petitioner believed her position (Trial Attorney IV, Item 59, P5,100.00 per annum) was third in rank, and the position vacated by Artemio Tobias (Item 58, P6,000.00) was next in rank to Chief Trial Attorney. She was offered the position vacated by Pio Guerrero (Item 60-2, P6,000.00), which she considered a demotion. The Commission also proposed to delete Roman numerals from position titles to consider them of the same category. Procedural History: Petitioner filed a petition for mandamus and prohibition with preliminary injunction before the Supreme Court to compel the respondents to grant her desired promotion and to prevent the proposed changes in position designations. The Court required respondents to answer but denied the preliminary injunction. The Petition: Petitioner sought a writ of mandamus to compel the respondents to revoke their resolution appointing Cayetano Jacinto to the position of Trial Attorney IV (Item 58) and to appoint her instead. She also sought a writ of prohibition to prevent the deletion of Roman numerals from position titles and the re-designation of a Trial Attorney II position. Her primary argument was that the budgetary law's itemization of positions reflected their category and rank, and that offering her a Trial Attorney II position, even with a higher salary, constituted a demotion, while appointing Jacinto to the higher-ranked Trial Attorney IV position was unjust.
Issue(s)
Whether the budgetary law's itemization of positions in the Reparations Commission dictates their category and rank for purposes of promotion and appointment. Whether the petitioner had exhausted all available administrative remedies before filing a petition for mandamus and prohibition with the Supreme Court.
Ruling
The petition is denied. The Court ruled that budgetary laws are primarily for appropriation and not for classifying government positions, with the Civil Service Law being the controlling statute. It also held that the petitioner failed to exhaust administrative remedies by not appealing to the Civil Service Commissioner.
Ratio Decidendi
On Issue 1: The Court held that budgetary laws, such as the General Appropriations Act, are primarily intended to set aside money for the support and operation of the government and do not control the classification of positions within government entities. The Court took judicial notice that statements of positions in budget proposals are merely for requesting appropriations and are not definitive for classification. The controlling statute for the classification of positions in the government service is the Civil Service Law and its implementing rules and regulations. Therefore, the petitioner's interpretation of the budgetary law as dictating the rank and category of positions was incorrect. On Issue 2: The Court found that the petitioner failed to exhaust all available administrative remedies before filing her petition for mandamus and prohibition. Section 16 of Republic Act No. 2260 (Civil Service Law) grants the Commissioner of Civil Service exclusive jurisdiction over the approval of appointments and promotions and the power to hear and determine appeals from aggrieved individuals. The petitioner's remedy was to appeal her grievance to the Civil Service Commissioner, whose decision would be final. Her failure to pursue this administrative remedy rendered her petition premature and flawed, as it bypassed the legally prescribed procedure for seeking redress in civil service matters.
Main Doctrine
The Court held that budgetary laws are primarily intended to set aside money for the support and operation of the government and are not controlling for the classification of positions within government entities. The controlling statute for position classification is the Civil Service Law and its implementing rules. Consequently, any employee aggrieved by an action of an appointing authority concerning appointments or promotions must first exhaust administrative remedies by appealing to the Civil Service Commissioner, whose decision is final, before seeking judicial intervention through a petition for mandamus or prohibition.