Civil Service Commission v. Magoyag
REITERATIONFacts
The Antecedents: Respondent Madlawi B. Magoyag sought to correct his date of birth in official records from July 22, 1947, to July 22, 1954. He claimed the discrepancy arose from a mistake made when he applied for employment in 1974. This incorrect date had been carried over into his records with the Government Service Insurance System (GSIS) and throughout his government service. Procedural History: Magoyag initiated proceedings by filing a petition for correction of his date of birth with the Regional Trial Court (RTC) of Lanao del Sur, which granted the petition on November 20, 2007, ordering corrections by the GSIS and the Bureau of Customs. This decision was later amended on June 2, 2008, to include directives for the Local Civil Registrar of Tamparan and the Civil Service Commission (CSC) to effect the correction. Subsequently, Magoyag requested the CSC to correct his employment records. The CSC initially denied this request, citing the RTC decision's lack of finality, and later denied his motion for reconsideration. Aggrieved, Magoyag filed a Petition for Review with the Court of Appeals (CA). The Petition: The Civil Service Commission, as petitioner, assails the CA's decision, arguing that its resolutions denying Magoyag's request were administrative in nature and thus not subject to review under Rule 43 of the Rules of Court. The CSC contended that it did not exercise quasi-judicial functions as no hearings were conducted. The Commission further argued that even if the resolutions were reviewable, the CA erred in ordering the CSC to comply with the RTC decision. The Supreme Court, however, found that the CSC's resolutions, by denying a right conferred by a court judgment, constituted quasi-judicial actions, making the Rule 43 petition proper and affirming the CA's decision.
Issue(s)
Whether the resolutions issued by the Civil Service Commission denying the respondent's request for correction of his date of birth are reviewable under Rule 43 of the Rules of Court. Whether the Court of Appeals erred in ordering the Civil Service Commission to comply with the Regional Trial Court's decision.
Ruling
The petition is denied for lack of merit. The Decision of the Court of Appeals and its Resolution are affirmed.
Ratio Decidendi
On the issue of reviewability under Rule 43: The Court held that the resolutions issued by the CSC were not mere administrative responses but were quasi-judicial actions. The denial of the respondent's request, which was based on a court judgment, effectively adjudicated on his right to have his records corrected. The CSC's admission that it did not conduct investigations or hearings before issuing these resolutions further supports the classification of its actions as quasi-judicial, as this process involves the exercise of discretion of a judicial nature. Therefore, the resort to Rule 43 of the Rules of Court was proper. The Court emphasized that a quasi-judicial function involves the power to determine what the law is and what the legal rights of the parties are, and then to adjudicate upon these rights based on ascertained facts, even if no formal hearing is conducted. The CSC's denial, particularly the second resolution after the respondent submitted proof of finality, went beyond mere administrative policy enforcement and constituted an adjudication of the respondent's claim. On the issue of compliance with the RTC decision: The Court affirmed the CA's ruling that the CSC is legally bound to acknowledge and give effect to the final judgment of the RTC. The Court reiterated the doctrine of finality of judgment, stating that once a judgment becomes final and executory, it becomes immutable and unalterable. The CSC's disregard of the RTC's final judgment was deemed a reversible error. The Court stressed that the purpose of courts is to put an end to controversies, and parties have a right to rely on final judgments as a definitive disposition of their cases. The CSC's unsubstantiated presumption regarding the improbability of the respondent's graduation age, which led to the denial, should have been raised in the RTC proceedings, not used as a basis to disregard a final court order. The RTC's decision, being an in rem proceeding validated through publication, binds the whole world and vests the court with jurisdiction.
Main Doctrine
The Civil Service Commission, in denying a request for correction of an entry based on a final and executory court judgment, acts within its quasi-judicial function, making its resolutions appealable under Rule 43 of the Rules of Court. A final judgment is immutable and unalterable.