Primary Holding
Regional Trial Courts have no jurisdiction to entertain cases involving the dismissal of officers and employees covered by the Civil Service Law, including employees of quasi-public corporations such as water districts created pursuant to Presidential Decree No. 198. The initial remedy of an aggrieved employee is to appeal to the Civil Service Commission within fifteen days, and thereafter to proceed via certiorari under Rule 65 of the Rules of Court.
Background
Petitioners were all Board Members of the Morong Water District (MOWAD), a quasi-public corporation created pursuant to Presidential Decree No. 198, known as the Provincial Water Utilities Act of 1973, as amended by P.D. No. 1479. Private respondent Edgar Sta. Maria was the General Manager of MOWAD since August 1984. The established rule is that water districts are quasi-public corporations whose officers and employees belong to the Civil Service, and the hiring and firing of their employees are governed by the Civil Service Law and Rules and Regulations.
History
1993-
Jan 18, 1993
Private respondent filed a Special Civil Action for Quo Warranto and Mandamus with Preliminary Injunction before the Regional Trial Court of Rizal, Branch 78, docketed as Sp. Civil Case No. 014-M, challenging his dismissal by petitioners.
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3 mos 8 days later
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Apr 26, 1993
Petitioners moved to dismiss on grounds of lack of jurisdiction and improper remedy; respondent Judge Arturo Marave denied the Motion to Dismiss on April 26, 1993, and the Motion for Reconsideration on June 9, 1993.
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Petitioners elevated the matter to the Supreme Court via a petition for certiorari under Rule 65, which was referred to the Court of Appeals for adjudication.
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Nov 24, 1993
The Court of Appeals dismissed the petition for lack of merit; its Resolution dated January 11, 1994 denied the Motion for Reconsideration.
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Petitioners filed the instant petition for review with the Supreme Court.
Facts
Petitioners Aniceto G. Mateo, Maximo San Diego, Quirino Mateo, Daniel Francisco, and Leonila Kuizon were all Board Members of the Morong Water District (MOWAD), a quasi-public corporation created pursuant to Presidential Decree No. 198, as amended. Upon complaint of some MOWAD employees, petitioners conducted an investigation on private respondent Edgar Sta. Maria, then General Manager of MOWAD since August 1984.
On December 13, 1992, private respondent was placed under preventive suspension, and Maximo San Diego was designated in his place as Acting General Manager. Private respondent was later dismissed on January 7, 1993. On December 14, 1992, petitioners allegedly stopped and prohibited private respondent from exercising his rights and performing his duties as General Manager, and designated Maximo San Diego as Acting General Manager. On December 15, 1992, while private respondent was out of office on official travel, petitioners allegedly conspired to remove him from office by forcibly destroying his office door and locking it with a replaced door-knob, preventing his access and entry.
On January 18, 1993, private respondent filed a Special Civil Action for Quo Warranto and Mandamus with Preliminary Injunction before the Regional Trial Court of Rizal, Branch 78, challenging his dismissal. The petition embodied three causes of action: (1) that his preventive suspension and replacement were done arbitrarily and without procedural due process; (2) that his termination on January 7, 1993 was done in conspiracy with the Board Members; and (3) that he was entitled to injunctive relief restraining petitioners from continuing to stop and prohibit him from exercising his rights and performing his duties as General Manager.
Petitioners moved to dismiss the case on two grounds: (1) the court had no jurisdiction over disciplinary actions of government employees, which is vested exclusively in the Civil Service Commission; and (2) quo warranto was not the proper remedy. Respondent Judge Arturo Marave denied the Motion to Dismiss and the subsequent Motion for Reconsideration. Petitioners then elevated the matter to the Supreme Court through a petition for certiorari under Rule 65, which was referred to the Court of Appeals for adjudication. The Court of Appeals dismissed the petition for lack of merit.
Arguments of the Petitioners
- Lack of Jurisdiction: Petitioners argued that the Regional Trial Court had no jurisdiction over disciplinary actions of government employees, such jurisdiction being vested exclusively in the Civil Service Commission.
- Improper Remedy: Petitioners argued that quo warranto was not the proper remedy for challenging the dismissal of a government employee.
Arguments of the Respondents
- Jurisdiction of the RTC: Private respondent Sta. Maria argued that the Regional Trial Court had jurisdiction over his Special Civil Action for Quo Warranto and Mandamus, asserting that he had a clear right to the Office of General Manager of MOWAD which was being usurped or unlawfully held by Maximo San Diego in conspiracy with his co-respondents.
- Due Process Violation: Private respondent alleged that his suspension and dismissal were done arbitrarily, whimsically, and unilaterally, contrary to the tenets of justice and fairness, and for want of procedural due process.
Issues
- Jurisdiction over Dismissal Cases: Whether the Regional Trial Court of Rizal has jurisdiction over Sp. Civil Case No. 014-M involving the dismissal of an employee of a quasi-public corporation.
Ruling
- Jurisdiction over Dismissal Cases: No. The Regional Trial Court has no jurisdiction over cases involving the dismissal of officers and employees covered by the Civil Service Law. Jurisdiction over such matters is vested exclusively in the Civil Service Commission, and the initial remedy of an aggrieved employee is to appeal to the Commission within fifteen days, thereafter proceeding via certiorari under Rule 65 of the Rules of Court.
Ruling Rationale
- Jurisdiction over Dismissal Cases: The Court held that there is no question that MOWAD is a quasi-public corporation created pursuant to Presidential Decree No. 198, known as the Provincial Water Utilities Act of 1973, as amended. Citing Davao City Water District vs. Civil Service Commission, the Court ruled that employees of government-owned or controlled corporations with original charter fall under the jurisdiction of the Civil Service Commission. The Court noted that as early as Baguio Water District vs. Trajano, it was already ruled that a water district is a corporation created pursuant to a special law — P.D. No. 198, as amended — and as such, its officers and employees are covered by the Civil Service Law. In Hagonoy Water District vs. NLRC, the Court ruled once again that local water districts are quasi-public corporations whose employees belong to the Civil Service. The established rule is that the hiring and firing of employees of government-owned and controlled corporations are governed by the provisions of the Civil Service Law and Rules and Regulations. Presidential Decree No. 807, Executive Order No. 292, and Rule II, Section 1 of Memorandum Circular No. 44, series of 1990, of the Civil Service Commission spell out the initial remedy of private respondent against illegal dismissal, categorically providing that the party aggrieved by a decision, ruling, order, or action of an agency of the government involving termination of services may appeal to the Commission within fifteen days. Thereafter, private respondent could go on certiorari to the Supreme Court under Rule 65 of the Rules of Court if he still feels aggrieved by the ruling of the Civil Service Commission, as held in Mancita vs. Barcinas. The Court noted that while Mancita no longer governs because under the present rule, Revised Circular No. 1-91 as amended by Revised Administrative Circular No. 1-95 which took effect on June 1, 1995, final resolutions of the Civil Service Commission shall be appealable to the Court of Appeals, in any event, whether under the old rule or present rule, Regional Trial Courts have no jurisdiction to entertain cases involving dismissal of officers and employees covered by the Civil Service Law.
Doctrines
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Jurisdiction over Civil Service Employees — Employees of government-owned or controlled corporations with original charters, including quasi-public corporations like water districts, fall under the jurisdiction of the Civil Service Commission. The hiring and firing of such employees are governed by the provisions of the Civil Service Law and Rules and Regulations, and Regional Trial Courts have no jurisdiction to entertain cases involving their dismissal.
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Exclusive Original Jurisdiction of the Civil Service Commission — The Civil Service Commission, under the Constitution, is the single arbiter of all contests relating to the Civil Service, and its judgments are unappealable and subject only to the Supreme Court's certiorari jurisdiction. The initial remedy of an aggrieved employee against illegal dismissal is to appeal to the Commission within fifteen days, and thereafter to proceed via certiorari under Rule 65 of the Rules of Court.
Key Excerpts
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"There is no question that MOWAD is a quasi-public corporation created pursuant to Presidential Decree (P.D.) No. 198, known as the provincial Water Utilities Act of 1973, as amended." — This passage establishes the foundational fact that MOWAD is a quasi-public corporation, which is the basis for determining that its employees fall under the Civil Service Law.
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"As early as Baguio Water District v. Trajano et, al., We already ruled that a water district is a corporation created pursuant to a special law — P.D. No. 198, as amended, and as such its officers and employees are covered by the Civil Service Law." — This passage articulates the controlling doctrine that water district employees are covered by the Civil Service Law, which is the ratio decidendi of the case.
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"In any event, whether under the old rule or present rule, Regional Trial Courts have no jurisdiction to entertain cases involving dismissal of officers and employees covered by the Civil Service Law." — This passage states the core holding of the case, that RTCs lack jurisdiction over dismissal cases of Civil Service employees regardless of the applicable appellate rule.
Precedents Cited
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Davao City Water District vs. Civil Service Commission, G.R. Nos. 95237-38, September 13, 1991, 201 SCRA 593 — Controlling precedent ruling that employees of government-owned or controlled corporations with original charter fall under the jurisdiction of the Civil Service Commission.
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Baguio Water District vs. Trajano — Followed precedent ruling that a water district is a corporation created pursuant to a special law, P.D. No. 198, and its officers and employees are covered by the Civil Service Law.
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Hagonoy Water District vs. NLRC — Followed precedent ruling that local water districts are quasi-public corporations whose employees belong to the Civil Service.
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Zamboanga City Water District vs. Buat, G.R. No. 104389, May 27, 1994, 232 SCRA 587 — Cited for the established rule that the hiring and firing of employees of government-owned and controlled corporations are governed by the provisions of the Civil Service Law and Rules and Regulations.
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Mancita vs. Barcinas, G.R. No. 98120, December 22, 1992, 216 SCRA 772 — Cited for the rule that no appeal lies from the decision of the Civil Service Commission and that parties aggrieved thereby may proceed to the Supreme Court alone on certiorari under Rule 65 within thirty days from receipt of a copy thereof, pursuant to Section 7, Article IX of the 1987 Constitution.
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Lopez, Jr. vs. Civil Service Commission, G.R. No. 87119, April 16, 1991, 195 SCRA 777 — Cited in Mancita for the proposition that the Civil Service Commission is the single arbiter of all contests relating to the Civil Service.
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Dario vs. Mison, G.R. Nos. 81954, 81967, 82023, 83737, 85310, 85335, & 86241, August 8, 1989, 176 SCRA 84 — Cited in Mancita for the proposition that the Civil Service Commission is the single arbiter of all contests relating to the Civil Service.
Provisions
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Presidential Decree No. 198 — Known as the Provincial Water Utilities Act of 1973, as amended by P.D. No. 1479; the law creating MOWAD as a quasi-public corporation, the basis for determining that its employees are covered by the Civil Service Law.
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Presidential Decree No. 807, Section 39 — Provides the initial remedy of an aggrieved employee against illegal dismissal, allowing appeal to the Civil Service Commission within fifteen days.
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Executive Order No. 292, Section 49(1) — Provides the initial remedy of an aggrieved employee against illegal dismissal, allowing appeal to the Civil Service Commission within fifteen days.
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Memorandum Circular No. 44, series of 1990, Rule II, Section 1 — Issued by the Civil Service Commission; categorically provides that the party aggrieved by a decision, ruling, order, or action of an agency of the government involving termination of services may appeal to the Commission within fifteen days.
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Section 7, Article IX, 1987 Constitution — Provides that any decision, order, or ruling of each Commission may be brought to the Supreme Court on certiorari by the party within thirty days from receipt of a copy thereof.
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Republic Act No. 6656, Section 8 — Provides that an officer or employee who is still not satisfied with the decision of the appointing authority may further appeal within ten days from receipt thereof to the Civil Service Commission, which shall render a decision thereon within thirty days and whose decision shall be final and executory.
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Rule 65, Rules of Court — The remedy available to an aggrieved party after the Civil Service Commission's ruling on a dismissal case.
Notable Concurring Opinions
Narvasa, C.J., Regalado, Mendoza, and Francisco, JJ., concurred.