Peralta v. Court of Appeals
REITERATIONFacts
The Antecedents: Israel G. Peralta (PERALTA), Director/Officer-in-Charge of the Parole and Probation Administration (PPA), Regional Office No. XII, Cotabato City, issued an Order on March 23, 1995, directing Nida Olegario (OLEGARIO), a Budget Officer I, and a co-employee to cease and desist from performing their duties effective April 1, 1995, and to go on leave due to alleged insufficiency in the release of allotment for their positions. PERALTA also directed the recall of semi-expendable equipment from OLEGARIO. Procedural History: OLEGARIO sought the opinion of the Civil Service Commission (CSC) Regional Office, which declared PERALTA's Order illegal and advised PERALTA to cease and desist from enforcing it. Despite this, PERALTA persisted, even directing security guards to prevent OLEGARIO from reporting for work. The CSC reiterated its ruling and ordered OLEGARIO's reinstatement. OLEGARIO filed a complaint for grave abuse of authority with the Office of the Ombudsman. PERALTA eventually issued a memorandum directing OLEGARIO to report back to work on July 21, 1995, after receiving the necessary allotment. The Ombudsman found PERALTA guilty of grave abuse of authority and imposed a penalty of one year suspension. The Court of Appeals (CA) denied PERALTA's petition for certiorari, affirming the Ombudsman's decision. PERALTA filed a petition for review on certiorari with the Supreme Court. The Petition: The Petition seeks the reversal of the CA's Decision and Resolution, arguing that the CA gravely abused its discretion in equating the power of the CSC Regional Director with that of the Commission itself, in applying the term "bad faith" to PERALTA's actions, and in affirming the Ombudsman's resolution.
Issue(s)
Whether the Court of Appeals gravely abused its discretion in dismissing the petition when it equated the power of the Regional Director of the Civil Service Commission with that of the Commission itself. Whether the Court of Appeals gravely abused its discretion tantamount to lack of jurisdiction when it applied the term "bad faith" to the act of the petitioner without taking into account the yardstick laid by the Supreme Court. Whether the Court of Appeals erred and/or committed a grave abuse of discretion tantamount to lack of jurisdiction in affirming the patently erroneous resolution of the Ombudsman.
Ruling
The Supreme Court denied the petition for review on certiorari and affirmed the Decision and Resolution of the Court of Appeals, with a modification directing petitioner Israel G. Peralta to pay the back salaries of respondent Nida Olegario from April 1, 1995, until July 21, 1995.
Ratio Decidendi
On the issue of the power of the CSC Regional Director: The Court held that the Regional Offices of the CSC are empowered to enforce Civil Service laws, rules, policies, and standards on personnel management within their jurisdiction. This power necessarily includes the authority to issue opinions and rulings regarding personnel management, which are binding on government agencies. The Court cited Section 13 of P.D. No. 807 and Section 16(15) of E.O. No. 292, emphasizing the mandate to enforce Civil Service Law and Rules. Therefore, the ruling of the CSC Regional Office that PERALTA's memorandum was contrary to existing Civil Service law and rules was binding upon him. The Court found no error in the CA's affirmation of this power. On the issue of bad faith: The Court was not persuaded by PERALTA's contention that he acted in good faith. It noted that PERALTA failed to refute OLEGARIO's allegation that he knew of the release of cash allotment for her salary as early as November 1994, yet proceeded to implement his memorandum. Even if no cash allotment was released, PERALTA could have simply followed up the matter with the central office and the DBM, rather than issuing a void order. The Court found that PERALTA overstepped his authority by executing and implementing his memorandum despite the CSC Regional Office's advice that it lacked legal basis. The Court reiterated that bad faith imputes a dishonest purpose or conscious doing of a wrong, a breach of sworn duty through some motive or intent or ill will. PERALTA's obstinate refusal to heed the CSC's directive, even after being reminded twice and ordered to reinstate OLEGARIO, demonstrated evident bad faith. The Court cited Sidro vs. People to define bad faith. On the affirmation of the Ombudsman's resolution: Given the findings on the binding nature of the CSC's rulings and PERALTA's evident bad faith, the Court found no error in the Ombudsman's conclusion that PERALTA was guilty of grave abuse of authority. The Court also applied the ruling in Constantino-David, et al. vs. Pangandaman-Gania regarding personal accountability for back salaries in cases of illegal dismissal or refusal to reinstate made in bad faith. Consequently, PERALTA was directed to pay OLEGARIO's back salaries from April 1, 1995, to July 21, 1995, as he unjustifiably barred her from reporting for work despite the CSC's order.
Main Doctrine
A government employee's obstinate and unjustified refusal to heed the directive of the Civil Service Commission (CSC) Regional Office, which is presumed to be the authority on personnel administration matters, overcomes the presumption of good faith and establishes bad faith, particularly when such refusal persists despite repeated advisement and orders.