Mabuhay v. Seriña
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the claim of Leo Y. Mabuhay for unpaid salaries as Acting City Engineer of Cagayan de Oro City. Mabuhay was initially designated to this position by President Diosdado Macapagal on October 3, 1963. His tenure was marked by several legal challenges and temporary restraining orders filed by Engineer Herminio Lucero, which temporarily prevented Mabuhay from exercising his functions. Despite these challenges, Mabuhay was re-designated on May 29, 1964, and continued to occupy the position until November 3, 1965, when Procopio Resabal was appointed City Engineer. 2. Procedural History: Mabuhay's claims for salary were initially submitted to administrative authorities. His claim for the period October 3, 1963, to May 21, 1964, was disallowed by the Deputy Auditor General on August 4, 1965, on the grounds that Engineer Lucero had discharged the duties and was paid, and that even if Mabuhay was a de facto officer, the government had already paid compensation. An appeal to the President was withdrawn. A subsequent claim for May 21, 1965, to June 30, 1965, was denied by the Deputy Auditor General on October 12, 1965, due to Congress not acting on his designation. This denial was upheld by the Executive Secretary on January 20, 1966. The Court of First Instance subsequently dismissed Mabuhay's petition for mandamus with damages, ruling that the administrative decisions were final and barred his claim, and that the Auditor General's actions involved discretion not controllable by mandamus. 3. The Petition: This case reached the Supreme Court via an appeal filed pursuant to Rule 42 of the Rules of Court. Mabuhay's petition argues that the lower court erred in holding that the opinions of the Deputy Auditor General and Executive Secretary barred his action for back salaries. He specifically contends that the lower court should have recognized him as a de facto officer from May 21, 1965, to November 3, 1965, and thus entitled to back salaries for that period. The appeal also challenges the dismissal of his petition and argues that the administrative decisions should not apply to all his claimed periods. The Supreme Court, however, found the appeal to be without merit, affirming the lower court's decision that the administrative decisions were final and that Mabuhay had not exhausted administrative remedies for certain periods.
Issue(s)
Whether the administrative decisions disallowing petitioner's salary claims are final and bar the present action. Whether mandamus can compel the passing in audit of a salary claim. Whether petitioner was a de facto officer from May 21, 1965, to November 3, 1965, and thus entitled to back salaries.
Ruling
The appeal is dismissed for lack of merit. The petition for mandamus is denied.
Ratio Decidendi
On the finality of administrative decisions: The Court held that the administrative decisions disallowing petitioner's salary claims were final and binding. The withdrawal of his appeal to the President regarding the first claim rendered the Deputy Auditor General's decision final. Similarly, the denial of his second claim by the Deputy Auditor General and the Executive Secretary, acting for the President, was definitive. These final administrative rulings could not be circumvented by filing a court action. The Court cited previous rulings in Mangonon and Sambo to support the principle that final administrative decisions are a bar to subsequent judicial actions. On the use of mandamus: The Court reiterated that mandamus is a remedy to compel the performance of a ministerial duty, not to control or review the exercise of judgment or discretion. Passing a salary voucher in audit is not a ministerial function; the Auditor General exercises discretion or a quasi-judicial power. Therefore, mandamus cannot be used to compel the Auditor General to pass in audit a salary claim, as established in Gonzales. The Court emphasized that administrative decisions can only be set aside upon proof of gross abuse of discretion, fraud, or error of law, none of which were present. On the de facto officer status and entitlement to salary: The Court found the claim for salary from May 21, 1965, to July 31, 1965, to have been definitively disallowed by the Auditor General and the Executive Secretary. Regarding the period from August 1, 1965, to November 3, 1965, the Court noted that the claim had not yet been passed upon by the Commission on Audit. Therefore, petitioner should have allowed that office to act on his claim before pursuing other remedies, making his suit premature. The Court also implicitly rejected the de facto officer argument by upholding the administrative denials and the premature filing of the suit.
Main Doctrine
Administrative decisions on claims, when final and rendered without grave abuse of discretion, fraud, or error of law, are binding and cannot be circumvented by filing a court action. Mandamus cannot compel the passing in audit of a salary claim as it involves discretion.