Does the Civil Service Commission or CSC have a legal standing to appeal to the Supreme Court a reversal or modification of its decision by the appellate court?
The Supreme Court was once again confronted with this issue in the recent case of CSC vs. Fuentes (Fuentes) [G.R. 237322, 10 January 2023].
In laying down the guidelines as to when the CSC can appeal a reversal of its decisions, the Court found it necessary to revisit the mandate of the CSC and its powers and functions, and did a survey of jurisprudence which involved the same issue.
The CSC’s role as the government’s central personnel agency is at the core of its mandate. From this overarching role stems all the others — the task to establish a career service; adopt measures to promote morale, efficiency, integrity, responsiveness, progressiveness, and courtesy in the civil service; strengthen the merit and rewards system; integrate all human resources development programs; institutionalize a management climate conducive to public accountability; and report to the President and the Congress.
Section 12, Chapter 3, Subtitle A, Title I, Book V of Executive Order No 292, otherwise known as the Administrative Code of 1987, enumerates the CSC’s powers and functions, which include, among others, the following:
SECTION 12. Powers and Functions. The Commission shall have the following powers and functions:
(6) Appoint and discipline its officials and employees in accordance with law and exercise control and supervision over the activities of the Commission;
(11) Hear and decide administrative cases instituted by or brought before it directly or on appeal, including contested appointments, and review decisions and actions of its offices and of the agencies attached to it.
In the Fuentes case, the Court concluded that the CSC cannot thoroughly perform its constitutional mandate of being a central personnel agency without its power to discipline its officials and employees, and held that “the Commission’s role of being a central personnel agency would be unduly crippled without its disciplinary power.”
The case of CSC vs Dacoycoy, G.R. No. 135805, 29 April 1999 (Dacoycoy):
Dacoycoy categorically abandoned the Supreme Court’s earlier decision ruling that the civil service law “does not contemplate a review of decisions exonerating officers or employees from administrative charges,” firmly expanded the scope of an “aggrieved party” and declared that, as a party adversely affected by the ruling of the Court of Appeals exonerating the public official or employee, the CSC may appeal the Court of Appeals’ decision to the Supreme Court.
The Supreme Court elucidated that under such circumstances, the CSC becomes an aggrieved party — a party adversely affected by the ruling of the Court of Appeals, which will “seriously prejudice the civil service system.”
The case of CSC vs Mathay Jr., G.R. 124374, 15 December 1999 (Mathay, Jr.):
Seven months after the Court’s promulgation of Dacoycoy, it decided on Mathay Jr.
In declaring that the CSC had no legal standing to bring an appeal before the Supreme Court, the latter drew a line between Mathay Jr. and Dacoycoy by ruling that, while Dacoycoy involved nepotism — an administrative case “whose deleterious effect on government cannot be overemphasized,” Mathay Jr. merely involved reinstatement, an issue that can hardly “impair the effectiveness of government.”
For this reason, the Supreme Court held that its ruling in Dacoycoy did not apply to Mathay Jr.
The reasoning of the Court behind Mathay Jr. stemmed from the fact that the CSC’s power to hear and decide administrative cases instituted by or brought before it directly or on appeal is judicial instead of adversarial. Hence, CSC is more of a judge than a litigant.
The Court went on to explain that as a quasi-judicial body with the role of an adjudicator, the CSC should be impartial and detached; and concluded that the CSC would risk becoming an advocate if it would be allowed to appeal to the Supreme Court.
