University of the Philippines v. Peña
REITERATIONFacts
The Antecedents: Camilo V. Peña and Domingo Cajipe, classified civil service employees of the Philippine General Hospital (PGH), were administratively charged with "grave misconduct and dishonesty" and "infidelity in the custody of public documents." After an investigation, a UP-PGH Investigating Committee submitted a report, which the Board of Regents adopted, resolving to dismiss Peña and Cajipe. Procedural History: Peña and Cajipe filed a Petition for Injunction with the Court of First Instance (CFI) of Manila, seeking to restrain their dismissal and to declare that their removal should be by the Civil Service Commissioner, not the UP President. The CFI issued a preliminary injunction, which was later made permanent. The University of the Philippines (UP) appealed to the Court of Appeals (CA), which affirmed the CFI's decision. UP then filed the instant petition for review by certiorari. The Petition: The sole issue raised by UP is whether the dismissal of respondents by the Board of Regents is final or requires further action by the Civil Service Commission.
Issue(s)
Whether the Board of Regents of the University of the Philippines has the final authority to dismiss employees of the Philippine General Hospital, or if such jurisdiction belongs exclusively to the Civil Service Commissioner under Republic Act No. 2260.
Ruling
The Supreme Court granted the writ of certiorari, reversed, and set aside the decisions of the Court of Appeals and the Court of First Instance. It ruled that the President and Board of Regents of the University of the Philippines possess full and final authority in the disciplining, suspension, and removal of the civil service employees of the University, including those of the Philippine General Hospital, independently of the Commissioner of Civil Service and the Civil Service Board of Appeals.
Ratio Decidendi
On Issue 1: The Court ruled that while the Civil Service Commissioner generally has exclusive jurisdiction over the removal of civil service employees, Section 16(i) of the Civil Service Act of 1959 explicitly allows for exceptions "as otherwise provided by law." The UP Charter (Act No. 1870, as amended) is one such law, providing in Section 6(e) that the Board of Regents has the power to remove employees for cause after investigation and hearing. This specific grant of power prevails over the general provisions of the Civil Service Law. Furthermore, the transfer of the Philippine General Hospital (PGH) to the University of the Philippines (UP) via Executive Order No. 94 (1947) evinced an intent to place PGH employees under the administrative power of the University. The Court emphasized that subjecting the PGH and the UP Medical College to different administrative controllers would impede the harmony and efficiency required for their academic and research missions. Applying the principle in Castillo v. Bayona, the Court held that special laws governing specific entities regarding investigation and removal must govern even if the employees are otherwise subject to Civil Service rules. Finally, since the respondents were afforded due process through fifty-nine hearings and a fair investigation, the University's decision to dismiss them is final and autonomous.
Main Doctrine
The President and Board of Regents of the University of the Philippines possess full and final authority in the disciplining, suspension, and removal of the civil service employees of the University, including those of the Philippine General Hospital, independently of the Commissioner of Civil Service and the Civil Service Board of Appeals, provided due process is observed.