University of the Philippines v. Regino
NEW DOCTRINEFacts
1. The Antecedents: Angel Pamplina, a mimeograph operator at the University of the Philippines School of Economics, was dismissed on June 22, 1982, after being found guilty of dishonesty and grave misconduct for leaking examination questions. His dismissal was upheld by the UP Board of Regents. 2. Procedural History: Pamplina appealed his dismissal to the Merit Systems Board (MSB), which exonerated him and ordered his reinstatement with back wages. The UP Board of Regents' motion for reconsideration was denied. UP then appealed to the Civil Service Commission (CSC), which sustained the MSB's decision. After UP's motion for reconsideration was denied, they filed a second motion for reconsideration, which the CSC also denied, citing a rule against entertaining more than one motion for reconsideration. When Pamplina sought execution of the CSC's judgment, UP resisted, claiming the resolutions were not final. Consequently, Pamplina filed a petition for a writ of mandamus with the Regional Trial Court (RTC), which ordered his reinstatement with back wages and other benefits. 3. The Petition: The University of the Philippines and the UP School of Economics filed this petition for certiorari with the Supreme Court, seeking to annul the RTC's decision and the CSC's orders directing Pamplina's reinstatement. They argue that under its charter (Act 1870), UP possesses institutional autonomy, granting the Board of Regents the power to appoint and remove employees. They contend that the CSC lacks appellate jurisdiction over administrative disciplinary cases involving UP employees. The petitioners also argue that their second motion for reconsideration was timely filed and that the CSC's resolutions had not become final and executory. The Supreme Court is asked to uphold the dismissal order issued by the UP President and Board of Regents.
Issue(s)
Whether the Civil Service Commission has appellate jurisdiction over administrative disciplinary cases involving UP employees. Whether UP's institutional autonomy exempts it from the appellate jurisdiction of the Civil Service Commission. Whether the second motion for reconsideration filed by UP was valid. Whether the resolutions of the Civil Service Commission had become final and executory, thus warranting the issuance of a writ of mandamus.
Ruling
The Supreme Court dismissed the petition for certiorari, affirmed the decision of the RTC granting the writ of mandamus, and upheld the challenged orders of the Civil Service Commission. The Court ordered the reinstatement of Angel Pamplina with back wages.
Ratio Decidendi
On the jurisdiction of the Civil Service Commission: The Court held that under Presidential Decree No. 807 (Civil Service Law), the Civil Service Commission (CSC) has appellate jurisdiction over administrative disciplinary cases involving employees of government-owned or controlled corporations with original charters, which includes the University of the Philippines (UP). The Court emphasized that under the 1973 Constitution, all government-owned or controlled corporations were considered part of the Civil Service, and UP, created by a special law with an original charter, falls under this classification. Therefore, administrative cases involving the discipline of its employees come under the appellate jurisdiction of the CSC. On UP's institutional autonomy: While acknowledging UP's institutional autonomy granted by its charter (Act 1870), the Court clarified that this autonomy does not exempt it from the appellate jurisdiction of the CSC in disciplinary cases. The Court distinguished the present case from University of the Philippines vs. Court of Appeals, noting that PD 807, which grants the CSC appellate jurisdiction, was enacted after the cited case. The Court found that Section 9(j) of PD 807 empowers the CSC to hear and decide administrative disciplinary cases brought to it on appeal, without the qualifying phrase present in the earlier Civil Service Law of 1959 that Justice J.B.L. Reyes relied upon in the earlier case. On the validity of the second motion for reconsideration: The Court ruled that the second motion for reconsideration filed by UP was invalid. Section 39(b) of PD 807 explicitly provides that "only one petition for reconsideration shall be entertained" by the CSC. Therefore, the CSC was correct in denying the second motion. On the finality and executory nature of the CSC resolutions: The Court found that the assailed orders of the CSC had become final and executory. Petitioners received a copy of the resolution denying their motion for reconsideration on April 22, 1988. Under Article IX-A, Section 7 of the 1987 Constitution, any decision, order, or ruling of a Commission may be brought to the Supreme Court on certiorari within thirty days from receipt. UP had until May 22, 1988, to file their petition. Instead, they filed a second motion for reconsideration on June 10, 1988, which was beyond the reglementary period and procedurally impermissible. Consequently, Pamplina had the right to seek mandamus to compel the execution of the final and executory resolutions.
Main Doctrine
The Civil Service Commission has appellate jurisdiction over administrative disciplinary cases involving employees of government-owned or controlled corporations with original charters, such as the University of the Philippines, notwithstanding its institutional autonomy. Failure to file a petition for certiorari within the reglementary period renders the decision final and executory, precluding further appeals or motions for reconsideration not allowed by law.