Civil Service Commission vs. Magoyag

Administrative resolutions that adjudicate rights conferred by final court judgments constitute quasi-judicial acts reviewable under Rule 43, and agencies may not circumvent the finality of judgments in rem by characterizing their compliance decisions as merely ministerial or administrative functions.

Respondent Madlawi B. Magoyag, a Collector of Customs II at the Bureau of Customs in Cagayan de Oro City, discovered that his employment records reflected a date of birth of July 22, 1947, allegedly due to an error when he completed an application form with Amanah Bank in 1974. This erroneous entry propagated through his government service records, including those of the Government Service Insurance System (GSIS) and the Civil Service Commission (CSC), despite his actual date of birth being July 22, 1954.

• The Correction Proceeding: Respondent Magoyag filed a petition for correction of entry with the RTC of Lanao del Sur, alleging that the discrepancy in his date of birth arose in 1974 when he mistakenly entered 1947 instead of 1954 in his application with Amanah Bank. This error propagated through his government employment records, including those of the GSIS and CSC.

• RTC Decision and Amendment: On November 20, 2007, the RTC granted the petition, ordering the GSIS and Bureau of Customs to correct their records to reflect July 22, 1954. On June 2, 2008, the RTC amended its decision to include the Local Civil Registrar of Tamparan, Lanao del Sur and the CSC as entities directed to effect the correction.

• Administrative Request to CSC: On February 6, 2008, respondent requested the CSC Regional Office No. X to correct his date of birth in employment records from July 22, 1947 to July 22, 1954. The request was forwarded to CSC-NCR and then to the CSC central office pursuant to CSC Resolution No. 04-0966.

• Supporting Documents Submitted: Respondent submitted his NSO certificate of live birth, the RTC decision, his sworn affidavit, a joint affidavit of attesting witnesses, his diploma from Central Philippine University (1967), transcript of records from Liceo de Cagayan University, and a Special Order from the Bureau of Private Schools.

• CSC Denial: The CSC denied the request in Resolution No. 090987 dated July 7, 2009, claiming the RTC decision was not yet final and executory. When respondent filed a motion for reconsideration attaching the Certificate of Finality issued by the RTC on June 17, 2008, the CSC denied it again in Resolution No. 100491 dated March 16, 2010.

• CSC's Basis for Denial: The CSC questioned the authenticity of respondent's educational records, noting that his transcript indicated graduation from college in November 1967, which would make him 13 years old at graduation if born in 1954. The CSC concluded this was manifestly improbable without conducting investigations or hearings to verify the possibility of early graduation.

• Nature of Function: Petitioner argued that Resolution Nos. 090987 and 100491 were mere responses to an administrative request, not exercises of quasi-judicial function. No investigations or hearings were conducted to ascertain facts; the resolutions merely enforced internal administrative policies and did not adjudicate rights.

• Impropriety of Rule 43: Assuming arguendo that the CSC was legally bound to comply with the RTC decision, resort to Rule 43 was inappropriate because the resolutions were not adjudications of rights but administrative enforcement of internal policies.

• Reviewability: Only judgments, final orders, or resolutions issued in the exercise of quasi-judicial functions are reviewable under Rule 43; administrative functions are excluded from such review.

• Quasi-Judicial Character: Whether Resolution Nos. 090987 and 100491 issued by the CSC constitute quasi-judicial acts reviewable under Rule 43 of the Rules of Court.

• Compliance with Final Judgment: Whether the Court of Appeals erred in ordering the CSC to comply with the final RTC decision correcting respondent's date of birth.

• Quasi-Judicial Character: The resolutions constitute quasi-judicial actions, not mere administrative responses. By denying the request even after respondent submitted the Certificate of Finality, the CSC adjudicated upon respondent's right conferred by the RTC judgment. The exercise of discretion to deny a right established by court decree transforms the administrative act into a quasi-judicial determination requiring investigation and hearing, particularly where the agency questions the validity of supporting documents.

• Compliance with Final Judgment: The Court of Appeals committed no reversible error. A petition for correction of entry is an action in rem that binds the whole world once final. The doctrine of finality of judgment requires that once a judgment attains finality, it becomes immutable and unalterable. The CSC, as an administrative agency, is legally bound to acknowledge and give effect to the final judgment of the RTC.

• Quasi-Judicial Function — An agency exercises quasi-judicial function when it has the power to determine what the law is and the legal rights of parties, investigates facts or ascertains the existence of facts, holds hearings, draws conclusions as a basis for official action, and exercises discretion of a judicial nature. Mere characterization of an act as administrative does not divest it of quasi-judicial character if the act effectively adjudicates rights conferred by judicial decree.

• Finality of Judgment — Once a judgment attains finality, it becomes immutable and unalterable; it may no longer be modified in any respect, even to correct perceived errors of fact or law. This doctrine is grounded on fundamental considerations of public policy and sound practice, ensuring that litigants have a right to rely on a final disposition of issues submitted.

• Action In Rem — A petition for correction of entry is an action against a thing, not a person. The decision binds not only the parties thereto but the whole world, validated essentially through publication. Such judgments are entitled to recognition and enforcement by all administrative agencies.

• "A[n agency] is said to be exercising judicial function where [it] has the power to determine what the law is and what the legal rights of the parties are, and then undertakes to determine these questions and adjudicate upon the rights of the parties."

• "This Court rules that the resolutions issued by petitioner are not mere responses to a request but are actually quasi-judicial actions because the result of those resolutions is the denial of a right of the respondent as conferred by the court."

• "It must be remembered that, a petition for correction is an action in rem, an action against a thing and not against a person. The decision on the petition binds not only the parties thereto but the whole world."

• "Nothing is more settled in law than that once a judgment attains finality it thereby becomes immutable and unalterable. It may no longer be modified in any respect, even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law."

• Tabigue, et al. v. International Copra Export Corporation (INTERCO), 623 Phil. 866 (2009) — Cited for the definition of quasi-judicial function as involving the power to determine legal rights and adjudicate upon them.

• Metropolitan Bank and Trust Company, Inc. v. National Wages and Productivity Commission, 54 Phil. 318 (2007) — Cited for the definition of quasi-judicial function involving investigation of facts and exercise of judicial discretion.

• Barco v. Court of Appeals, 465 Phil. 39 (2004) — Cited for the principle that a petition for correction of entry is an action in rem binding the whole world.

• Pasiona, Jr. v. Court of Appeals, et al., 581 Phil. 124 (2008) — Cited for the doctrine of finality of judgment and the public policy considerations underlying it.

• Juani v. Alarcon, 532 Phil. 585 (2006) — Cited for the immutability of final judgments and the prohibition against modifications even by the rendering court.

• Peña v. Government Service Insurance System, 533 Phil. 670 (2006) — Cited for the principle that the right of the winning party to enjoy finality of resolution is an essential part of public policy.

• Rule 43, Section 1, Rules of Court — Governs appeals from awards, judgments, final orders or resolutions of any quasi-judicial agency in the exercise of its quasi-judicial functions.

• Section 13, Article VIII, 1987 Constitution — Cited in the attestation regarding consultation among justices before assignment of opinion writing.

Maria Lourdes P.A. Sereno (Chairperson), Martin S. Villarama, Jr., Jose Portugal Perez, Bienvenido L. Reyes, and Diosdado M. Peralta (ponente).