GR L 18978; (May, 1964) (Digest)

G.R. No. L-18978; May 25, 1964
MANUEL MORATA, petitioner, vs. THE COURT OF APPEALS and MANRIQUE RAYMUNDO, respondents.

FACTS

Manuel Morata was the Chief of Police of Bulan, Sorsogon. On November 25, 1957, he was suspended due to an administrative complaint. While under suspension, then-Mayor Eulogio Santos appointed Manrique Raymundo as Chief of Police on November 25, 1958. This appointment was later approved by the Office of the President on April 20, 1960. Meanwhile, the Commissioner of Civil Service, in a decision dated January 22, 1959, found Morata guilty and considered him “resigned effective on the date of his suspension” (November 25, 1957). Morata received a copy of this decision on April 4, 1960, and filed a motion for reconsideration on May 3, 1960.
When a new mayor, Rosendo Haylo, assumed office on January 1, 1960, he terminated Raymundo and reinstated Morata. Raymundo then filed a Quo Warranto action against Morata. The Court of Appeals ruled that Morata’s reinstatement was void as it contravened the Civil Service Commissioner’s decision which deemed him resigned as of 1957. However, it also upheld Raymundo’s right to the office.

ISSUE

The core issue is whether either Manuel Morata or Manrique Raymundo is lawfully entitled to the office of Chief of Police of Bulan, Sorsogon.

RULING

The Supreme Court modified the decision of the Court of Appeals, ruling that neither party was entitled to the office. The Court agreed that Morata’s reinstatement on January 1, 1960, was invalid. The Civil Service Commissioner’s decision, which considered him resigned effective November 25, 1957, was binding. Even though the decision was formally served on April 4, 1960, and a motion for reconsideration was pending, its legal effect retroacted to the date of his suspension. Therefore, the mayor had no authority to reinstate Morata in January 1960.
However, the Court also ruled that Raymundo’s appointment on November 25, 1958, was null and void ab initio. At the time of his appointment, Morata, though under suspension, was still the incumbent. The office was not legally vacant. A void appointment cannot be cured or validated by a subsequent event, such as the later Civil Service decision declaring Morata’s resignation. Since Raymundo’s appointment was legally non-existent from the start, he acquired no right to the office. Consequently, neither individual had a valid claim to the position.