G.R. No. 209052 , June 23, 2021
Republic of the Philippines (Department of Education), Petitioner, vs. Eulalia T. Maneja, Respondent.

FACTS

Respondent Eulalia T. Maneja, a Secondary School Teacher, was authorized by Lyn Galarrita Cutamora to process Cutamora’s salary loan. Maneja processed the loan, received a check for the net proceeds, deposited it into her own account without Cutamora’s endorsement, and appropriated the amount. Cutamora filed a complaint for dishonesty. The Civil Service Commission Regional Office (CSCRO) No. X found Maneja guilty of dishonesty and imposed the penalty of dismissal. Maneja appealed to the Civil Service Commission (CSC) Proper. Pending appeal, the CSCRO’s dismissal order was implemented in December 2003. During the pendency of the appeal, the CSC issued Resolution No. 06-0538, classifying dishonesty into serious, less serious, and simple, with corresponding penalties. The CSC Proper later modified the CSCRO’s decision, finding Maneja liable only for Simple Dishonesty and imposing a three-month suspension. Maneja then moved for payment of back salaries from the time of her dismissal until reinstatement. The CSC initially denied but later granted her claim for backwages. The Department of Education (DepEd) assailed this grant before the Court of Appeals, which dismissed the petition. DepEd elevated the case to the Supreme Court.

ISSUE

1. Whether CSC Resolution No. 06-0538, which classifies the offense of dishonesty, is a valid exercise of the CSC’s rule-making power.
2. Whether respondent Maneja is entitled to backwages despite not being fully exonerated on appeal, given the premature execution of the dismissal order.

RULING

1. Yes, CSC Resolution No. 06-0538 is a valid exercise of the CSC’s quasi-legislative or rule-making power. The CSC, as the central personnel agency, has the power to implement civil service laws and promulgate policies. The resolution, which classifies dishonesty and provides corresponding penalties, is in harmony with Executive Order No. 292 (the Administrative Code), which lists dishonesty as a ground for disciplinary action but does not prescribe penalties. The resolution did not override but implemented the law.
2. Yes, respondent Maneja is entitled to backwages. The dismissal order imposed by the CSCRO was immediately executed pending her appeal to the CSC Proper. Under the Uniform Rules on Administrative Cases in the Civil Service (URACCS), a decision imposing removal is executory only after confirmation by the Secretary concerned when appealed to the CSC Proper. Since the CSCRO’s dismissal order was executed without such confirmation, it was premature. Consequently, Maneja is entitled to back salaries and other emoluments from the time of her wrongful dismissal until her reinstatement, deducting the period corresponding to the penalty of three-month suspension ultimately imposed. The conditions for backwages outlined in prior jurisprudence (requiring exoneration and unjustified suspension) do not apply in this context of premature execution of a penalty pending appeal.