G.R. No. 95246; June 19, 1991
BLANCA R. MARCAYDA, petitioner, vs. THE CIVIL SERVICE COMMISSION, THE HON. PRESS SECRETARY, THE DIRECTOR OF THE NATIONAL PRINTING OFFICE, OPS REORGANIZATION APPEALS BOARD, (OPS-RAB) and VERONICA A. BALCOS, respondents.

FACTS

Pursuant to Executive Order No. 285, the Government Printing Office (GPO) and relevant printing units of the Philippine Information Agency were merged to create the National Printing Office (NPO). Petitioner Blanca R. Marcayda and private respondent Veronica A. Balcos, both permanent employees of the GPO, were retained in a hold-over capacity pending reappointment to the new NPO staffing pattern. Marcayda was initially excluded from the new pattern and advised to retire. She appealed to the Civil Service Commission (CSC). Pending this appeal, the NPO Placement Committee found her appeal meritorious and recommended her reappointment as Budget Officer II, a position comparable to her former Budget Examiner III post. The CSC approved this appointment on September 23, 1988.
Balcos protested Marcayda’s appointment before the OPS Reorganization Appeals Board (OPS-RAB). This protest, together with Marcayda’s appeal, was consolidated in the CSC as CSC Case No. 271. On May 5, 1989, the CSC rendered a resolution finding Balcos’s protest without merit, ruling that both parties were validly reappointed to comparable positions under the reorganization law. No motion for reconsideration or appeal was filed by Balcos, rendering the CSC resolution final.

ISSUE

May the Civil Service Commission validly set aside its own final and executory decision?

RULING

No. The Supreme Court granted the petition, annulling the subsequent CSC resolutions. The Court emphasized the doctrine of finality of judgments, which applies with equal force to administrative tribunals. The CSC’s May 5, 1989 resolution in CSC Case No. 271 had attained finality when Balcos failed to file a motion for reconsideration or an appeal within the reglementary period. Consequently, the CSC lost its jurisdiction to alter, amend, or revoke that final decision.
The legal logic is anchored on the constitutional mandate for the Civil Service Commission to decide administrative cases within a specified period, after which such decisions become final and executory. The Court held that allowing the CSC to reopen and reverse a final decision based on a belated agency-level recommendation from the OPS-RAB—which was itself rendered after the CSC’s final ruling—would violate settled principles of administrative finality and stability of judgments. It would create an untenable situation where a subordinate body (OPS-RAB) could effectively nullify a final ruling of the constitutional commission (CSC). The Press Secretary’s subsequent memorandum affirming the OPS-RAB recommendation could not revive or supersede the CSC’s prior final resolution. Therefore, Marcayda’s appointment as Budget Officer II was upheld as valid and lawful.