G.R. No. L-15663; August 31, 1962
ANTONIO GUISADIO, petitioner-appellee, vs. RUBEN A. VILLALUZ, F.D. SINGCULAN and ANDRES SAJUL, respondents-appellants

FACTS

Antonio Guisadio was a chauffeur-examiner and acting registrar of the Motor Vehicles branch in Cebu City. On December 19, 1958, he received a letter from his superiors, respondents herein, transmitting a decision from the Commissioner of Civil Service which “considered Guisadio resigned from the service.” The letter directed him to immediately turn over all property accountabilities and vacate his post. Guisadio, contending he had not yet received the full text of the decision and that it was not yet final, filed a petition in the Court of First Instance of Cebu on the same day to enjoin the respondents from effecting his separation.
The respondents answered that they were merely implementing the orders of the Civil Service Commissioner, argued for immediate execution in the public interest, and claimed the Commissioner was an indispensable party. Subsequently, on January 5, 1959, Guisadio received the full decision and promptly filed a motion for reconsideration on January 8, 1959. The trial court, presided by Judge Modesto R. Ramolete, ruled in favor of Guisadio and issued the injunction.

ISSUE

Whether the trial court correctly enjoined the respondents from enforcing the Civil Service Commissioner’s decision and ousting Guisadio from his position during the pendency of his motion for reconsideration and potential appeal.

RULING

The Supreme Court affirmed the trial court’s judgment. The legal logic is anchored on the principle of finality and executory nature of administrative decisions. The Court held that the decision of the Civil Service Commissioner had not yet become final and executory at the time the respondents sought to enforce it. Guisadio retained the right to file a motion for reconsideration with the Commissioner and, if denied, to appeal to the Civil Service Board of Appeals. The law allows these administrative remedies, and until they are exhausted or the decision becomes final, execution is premature.
The Court rejected the respondents’ arguments. First, the Commissioner of Civil Service was not an indispensable party to the injunction suit because Guisadio was not seeking a judicial review of the merits of the administrative decision itself. His action was narrowly tailored to question only the premature execution of that non-final decision by his immediate superiors. Second, the respondents’ claim of public interest for immediate execution was unfounded, as the orderly administration of justice requires respecting the period for seeking reconsideration and appeal. The fact that Guisadio’s appeal might have been dismissed by the Board of Appeals during the pendency of the case before the Supreme Court was deemed irrelevant, as the correctness of the trial court’s order must be judged based on the facts existing at the time it was rendered. At that time, the administrative decision was clearly not final. Therefore, the injunction was proper.