Feliciano v. Villasin
REITERATIONFacts
The Antecedents: Petitioner Engr. Ranulfo C. Feliciano was appointed General Manager (GM) of the Leyte Metropolitan Water District (LMWD) in 1975. In 1990, the Local Water Utilities Administration (LWUA) took over LMWD's management due to financial default. During this period, administrative charges were filed against Feliciano for allegedly authorizing payment of his backwages despite not reporting for work. The Office of the Government Corporate Counsel (OGCC) found Feliciano guilty of grave misconduct, dishonesty, and conduct unbecoming an LMWD official, recommending dismissal, which the Interim LMWD Board of Directors approved in 1991. Procedural History: After the LWUA's takeover was lifted in 1998, Feliciano was re-appointed GM. However, his subsequent appointments of personnel were disapproved by the Civil Service Commission (CSC) Regional Office, and later by the CSC itself, which deemed him a de facto officer without the authority to appoint. Feliciano's appeals to the Court of Appeals and the Supreme Court (in G.R. No. 174178) regarding these CSC resolutions were denied. Subsequently, the CSC issued a resolution ordering Feliciano to vacate his position as GM, declaring him a usurper. Following this, the LMWD Board appointed respondent Nestor P. Villasin as the new GM. Feliciano then filed a Petition for Quo Warranto with the Regional Trial Court (RTC) to regain his position and have Villasin removed. The Petition: The RTC dismissed Feliciano's Petition for Quo Warranto, first for lack of cause of action and then for prematurity, as the issue of his status was still pending in higher courts. Feliciano then filed the instant Petition for Certiorari under Rule 65 of the Revised Rules of Court, assailing the RTC's dismissal orders. He argues that the RTC committed grave abuse of discretion. The Supreme Court, however, noted that Feliciano failed to implead the RTC as a respondent and that his case involved forum shopping, having pursued multiple avenues for the same relief. The Court ultimately found no grave abuse of discretion on the part of the RTC and affirmed its dismissal of the Quo Warranto petition, also reprimanding Feliciano and his counsel for forum shopping.
Issue(s)
Whether the RTC committed grave abuse of discretion amounting to lack or excess of jurisdiction in dismissing Feliciano's Petition for Quo Warranto. Whether Feliciano, as GM of LMWD, is covered by Civil Service Rules and Regulations requiring CSC attestation for his appointment. Whether Feliciano engaged in forum shopping.
Ruling
The Supreme Court dismissed the Petition for Certiorari, affirming the RTC's Orders dated July 28, 2006, and September 8, 2006, which dismissed Feliciano's Petition for Quo Warranto. The Court found no grave abuse of discretion on the part of the RTC. Feliciano and his counsel were reprimanded for forum shopping.
Ratio Decidendi
On the RTC's dismissal of the Petition for Quo Warranto: The Court held that the RTC did not commit grave abuse of discretion. A petition for Quo Warranto requires the petitioner to prove their entitlement to the office. In this case, Feliciano's claim to the GM position was already undermined by previous CSC resolutions and Supreme Court decisions (G.R. No. 172141) which declared him a de facto officer and a usurper, ordering him to vacate the position. Therefore, the RTC correctly dismissed the petition on its face for lack of cause of action and prematurity, as it was apparent that Feliciano was not entitled to the office. The RTC was not compelled to proceed with the trial when the petition was insufficient from the outset. On whether Feliciano is covered by Civil Service Rules: The Court affirmed that the General Manager of a water district, like LMWD, is covered by Civil Service Rules and Regulations. Presidential Decree No. 1479, issued on June 11, 1978, removed the exemption previously granted to water districts and their employees from the Civil Service Law. Subsequent amendments and jurisprudence, including Article IX-B, Section 2 of the Constitution, classify water districts as government instrumentalities whose officers and employees belong to the civil service. Therefore, Feliciano's appointment as GM required CSC attestation for validity. On forum shopping: The Court found that Feliciano engaged in forum shopping. He had filed multiple cases and petitions concerning the legality of his termination and claim to the GM position, creating the possibility of conflicting decisions. The Court reiterated that forum shopping is a vexation to the courts and parties-litigants and is a ground for dismissal and disciplinary action. Feliciano's continued pursuit of the petition despite the finality of G.R. No. 172141, which upheld the CSC resolution ordering him to vacate, demonstrated a willful disregard for the rules against forum shopping.
Main Doctrine
A petition for Quo Warranto may be dismissed at any stage if it becomes apparent that the petitioner is not entitled to the disputed public office. The dismissal of a Quo Warranto petition based on the petitioner's lack of legal standing or cause of action does not constitute grave abuse of discretion. Furthermore, repeated filing of similar cases in different fora constitutes forum shopping, which is a ground for dismissal and may warrant reprimand.