GR 185749; (December, 2009) (Digest)
G.R. No. 185749 ; December 16, 2009
CIVIL SERVICE COMMISSION, Petitioner, vs. HERMINIGILDO L. ANDAL, Respondent.
FACTS
Respondent Herminigildo L. Andal, a Security Guard II at the Sandiganbayan, applied for and passed the Career Service Professional Examination. An incident arose when Arlene S. Vito, claiming authorization from respondent, attempted to secure his examination results. Verification revealed dissimilarities between the facial features in the photographs on the Picture Seat Plan and respondent’s identification card, prompting an investigation for alleged impersonation. The CSC-NCR formally charged respondent with dishonesty. Despite notices sent to his last known address, respondent failed to appear at the scheduled hearings, leading to an ex parte proceeding. The CSC-NCR found him guilty and imposed the penalty of dismissal, which the CSC Commission Proper affirmed.
Respondent elevated the case to the Court of Appeals via a petition for review. The appellate court set aside the CSC’s resolutions, ruling that the CSC lacked disciplinary jurisdiction over a member of the judiciary. The CSC filed the present petition, arguing it retains jurisdiction over administrative cases involving civil service examination anomalies as part of its constitutional mandate to administer the civil service and protect its integrity.
ISSUE
Whether the Civil Service Commission has disciplinary jurisdiction to try and decide administrative cases against court personnel.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The Court held that while the CSC, as the central personnel agency, has broad administrative powers over the civil service, including the administration of examinations, the Constitution grants the Supreme Court exclusive administrative supervision over all courts and their personnel under Section 6, Article VIII. This constitutional power of supervision encompasses the authority to discipline judiciary employees.
The CSC’s invocation of its rules granting original disciplinary jurisdiction over cases involving examination anomalies cannot prevail over the Supreme Court’s constitutional mandate. The proper procedure was for the CSC to refer the administrative case to the Office of the Court Administrator for appropriate action. The Court clarified that this jurisdictional delineation does not preclude the filing of an administrative case against respondent; it merely designates the proper forum. Consequently, the CSC was ordered to refer the case to the Office of the Court Administrator. The ruling emphasizes the Court’s commitment to maintaining the integrity of the judiciary while respecting the constitutional separation of administrative authority.