G.R. No. 101646 February 13, 1992
DR. MARIQUITA J. MANTALA, petitioner, vs. HON. IGNACIO L. SALVADOR, Judge, Regional Trial Court of Quezon City, and DR. JULIA P. REGINO, respondents.

FACTS

Dr. Mariquita J. Mantala was given a temporary, and later a permanent, appointment as Division Chief in the Department of Health by Secretary Alfredo Bengzon. Dr. Julia P. Regino, claiming to be the next-in-rank officer, filed a protest with the Department’s Committee on Evaluation and Protest, which ruled in favor of Dr. Mantala. Dr. Regino appealed to the Merit Systems Protection Board, which reversed the decision in her favor. The Department appealed to the Civil Service Commission.
The Civil Service Commission initially affirmed the Board’s decision but, upon motion for reconsideration, reversed itself in Resolution No. 90-1012 dated November 14, 1990. The Commission upheld Dr. Mantala’s appointment, finding she outscored Dr. Regino in overall qualifications and deferring to the appointing authority’s discretion. Dr. Regino’s motion for reconsideration was denied, and she did not appeal this resolution, allowing it to become final and executory.

ISSUE

Whether the Regional Trial Court had jurisdiction to entertain a quo warranto and mandamus action concerning the appointment to a contested civil service position after the Civil Service Commission had rendered a final and executory resolution on the matter.

RULING

No, the Regional Trial Court had no jurisdiction. The Supreme Court annulled the RTC decision, ruling it was rendered without jurisdiction and contravened established doctrine.
The legal logic is grounded on the Constitution and civil service rules, which vest the Civil Service Commission with exclusive appellate jurisdiction over contested appointments and personnel actions in the civil service. The Commission’s Rules on Protest Cases explicitly grant it final and exclusive appellate jurisdiction over cases decided by the Merit Systems Protection Board involving contested appointments. A quo warranto action questioning the title to a civil service position falls within this exclusive administrative domain.
Dr. Regino’s proper remedy after the Commission’s final Resolution was to elevate the matter to the Supreme Court via a petition for certiorari under Rule 65 within the reglementary period. By failing to do so and allowing the Resolution to become final, she could not circumvent this administrative process by filing a collateral action in the RTC. The RTC’s assumption of jurisdiction violated the doctrine of primary jurisdiction and the finality of the Commission’s administrative decision.
On the merits, the Supreme Court also found the RTC decision erroneous, as it improperly substituted its judgment for that of the appointing authority and the Commission. The Court reiterated the doctrine that the appointing authority possesses wide discretion in choosing an appointee from among qualified candidates, and the Civil Service Commission cannot revoke an appointment merely because it believes another candidate is better qualified, provided the appointee meets the legal qualifications.