Board of Regents, Mindanao State University v. Osop
REITERATIONFacts
1. The Antecedents: This case concerns the employment status of Abedin Limpao Osop, who retired from the Mindanao State University (MSU) in 1987. Several years later, he was appointed as a substitute professor in the Electrical Engineering Department at MSU-General Santos City (MSU-GSC) starting July 1, 1994. His appointment was renewed annually, and he was even designated as Chairperson of the department. However, in July 1998, the then-Chancellor, Macapado A. Muslim, issued a letter and memorandum terminating Osop's services, citing the return of the professor he substituted for and the expiration of his temporary appointment. 2. Procedural History: Osop filed a complaint for injunction with damages against Chancellor Muslim and Dean Virgilio Ramos before the Regional Trial Court (RTC). The RTC dismissed the case for lack of jurisdiction, ruling that such matters fall under the Civil Service Commission. Osop appealed to the Court of Appeals (CA), which reversed the RTC's decision, finding that Osop's termination violated due process and that the RTC had erred in dismissing the case. The Supreme Court denied the petition for review filed by Muslim. Subsequently, Osop amended his complaint to implead MSU. The RTC granted Osop's motion for summary judgment, ordering MSU and the other defendants to provide Osop with teaching loads and pay damages. Muslim and MSU filed petitions for certiorari with the CA, challenging the RTC's orders. The CA dismissed Muslim's petition and declared MSU's motion to intervene as a stray pleading, leading to the present petition before the Supreme Court. 3. The Petition: The Board of Regents of the Mindanao State University, represented by its Chairman, filed this Petition for Review under Rule 45 of the Rules of Court. The petitioner assails the Court of Appeals' Decision dated March 14, 2006, which dismissed the petition for certiorari filed by Dr. Macapado A. Muslim and declared MSU's motion for intervention as a stray pleading. The petitioner argues that the Court of Appeals erred in holding that its motion for intervention was improvidently filed, that Osop's motion for summary judgment was proper despite factual issues requiring trial, that Osop acquired permanent status, and that the trial court's order granting partial execution was upheld.
Issue(s)
Whether the Court of Appeals gravely erred in holding that Petitioner MSU's Motion for Intervention was improvidently filed. Whether the Court of Appeals gravely erred in holding that Respondent Osop's Motion for Summary Judgment was proper despite Petitioner MSU presenting defenses that tendered factual issues requiring trial on the merits; and whether the Court of Appeals gravely erred in upholding the trial court's order granting Respondent Osop's Motion for Issuance of Partial Writ of Execution. Whether the Court of Appeals gravely erred in holding that Respondent Osop acquired permanent status.
Ruling
The Supreme Court denied the Petition for Review. The Court affirmed the Court of Appeals' dismissal of MSU's Motion for Intervention as a stray pleading. The Court also upheld the RTC's summary judgment and subsequent orders for execution, finding that the RTC orders had become final and executory as to MSU.
Ratio Decidendi
On the dismissal of MSU's Motion for Intervention: The Supreme Court held that MSU's Motion for Intervention in CA-G.R. SP No. 82052 was correctly dismissed by the Court of Appeals as a stray pleading. MSU was already impleaded as a defendant in the original Civil Case No. 6381 before the RTC and had participated in the proceedings through its counsel. The RTC issued adverse orders on March 20, 2003, and August 21, 2003, which became final and executory as to MSU after it failed to appeal or file a petition for certiorari within the reglementary periods. MSU's attempt to intervene 16 months after receiving the adverse RTC order was clearly beyond the prescribed periods for appeal or certiorari. Therefore, MSU could not circumvent the finality of the RTC orders by seeking to intervene in a separate petition filed by Muslim. On the propriety of the summary judgment and execution: The Supreme Court found no grave abuse of discretion on the part of the RTC in granting the summary judgment and subsequently issuing orders for execution. The Court reiterated that a summary judgment is final and disposes of the case, leaving nothing more to be done by the court except for the determination of damages. The RTC's March 20, 2003 Order granting summary judgment had become final and executory as to Muslim, et al. after they filed several motions for reconsideration that did not toll the reglementary period to appeal. The subsequent orders for execution, including execution pending appeal, were ministerial duties of the trial court once a judgment attained finality. The Court emphasized that the right to appeal is a statutory remedy and must be exercised within the time frame provided by law; failure to do so renders the decision final and executory, vesting rights in the winning party. On Osop's status: The Supreme Court noted that the Court of Appeals, in a previous decision (CA-G.R. SP No. 49966), had already made a finding that Osop's appointment ceased to be probationary in character and that he had acquired permanent status. The RTC, in granting the summary judgment, merely took judicial notice of these findings, which had become the "law of the case" between the parties. The Court found that the issue of Osop's status as a contractual employee, as raised by Muslim, et al., was patently unsubstantial and had already been settled by the appellate court's decision, which had become final and executory. Therefore, there was no genuine issue of fact left to be tried concerning Osop's status.
Main Doctrine
The Court of Appeals correctly dismissed the motion for intervention as a stray pleading because the intervenor (MSU) was already a party to the original case and had failed to timely appeal or file a petition for certiorari, rendering the RTC orders final and executory as to it. Furthermore, the Court reiterated that a summary judgment, once final and executory, becomes the ministerial duty of the trial court to execute.