G.R. No. 198404 , October 14, 2019
MELVIN G. SAN FELIX, PETITIONER, V. CIVIL SERVICE COMMISSION, RESPONDENT.

FACTS

On March 8, 2001, the CSC Regional Office No. 6 charged petitioner Melvin G. San Felix with dishonesty for allegedly conspiring with and allowing another person to take, in his behalf, the Police Officer I Examination held on March 29, 1998. The CSC noted discrepancies between the picture and signature in San Felix’s application form and seat plan compared to those in his Personal Data Sheet (PDS). In his Answer, San Felix denied the charge, insisting he personally took the examination and suggesting a possible mix-up of pictures. He filed a Motion to Dismiss, arguing that under the ruling in Civil Service Commission v. Court of Appeals, the CSC had been divested of authority to conduct police entrance examinations. The CSC Regional Office denied the motion and, after investigation, found him guilty of dishonesty, imposing the penalty of dismissal with accessory penalties. The CSC Proper and the Court of Appeals affirmed the decision, sustaining the CSC’s jurisdiction to investigate the anomaly and impose sanctions.

ISSUE

Whether or not the Civil Service Commission has jurisdiction to conduct investigations and render administrative decisions based on alleged anomalies in police entrance examinations.

RULING

Yes, the Civil Service Commission has jurisdiction. The Court ruled that the CSC, as the central personnel agency of the government, is vested with constitutional and statutory authority to administer and enforce the merit system, control and supervise civil service examinations, and hear and decide administrative cases. While the Supreme Court in Civil Service Commission v. Court of Appeals nullified Item No. 3 of CSC Resolution No. 96-5487 and ordered the CSC to desist from further conducting police entrance and promotional examinations, it did not divest the CSC of its jurisdiction to investigate anomalies committed in examinations it had previously administered. The CSC’s acts, including the administration of the March 29, 1998 examination, enjoyed a presumption of regularity from the issuance of the resolution on August 26, 1996 until the promulgation of the Supreme Court’s decision on September 25, 2001. Furthermore, the Court found substantial evidence, including discrepancies in photographs and signatures, to support the finding of dishonesty. The penalty of dismissal was affirmed, but the accessory penalty of forfeiture of retirement benefits was modified to exclude accrued leave credits. The petition was denied.