GR 107370 71; (September, 1993) (Digest)
G.R. Nos. 107370-71 September 16, 1993
MARIO A. NAVARRO, petitioner, vs. CIVIL SERVICE COMMISSION and EXPORT PROCESSING ZONE AUTHORITY, respondents.
FACTS
Petitioner Mario A. Navarro, a Police Officer of the Export Processing Zone Authority (EPZA), was administratively charged with grave misconduct for his alleged involvement in the theft of cable drums from the Bataan Export Processing Zone. The Senior Deputy Administrator of EPZA, upon recommendation, issued an Order terminating Navarro’s services. Navarro appealed to the Merit Systems Protection Board (MSPB) of the Civil Service Commission. The MSPB set aside the dismissal order and directed Navarro’s reinstatement with back wages. EPZA moved for reconsideration, which was denied by the MSPB. Meanwhile, the criminal case for qualified theft filed against Navarro and others was dismissed by the Regional Trial Court. EPZA then appealed the MSPB decision to the Civil Service Commission (CSC). The CSC set aside the MSPB decision, found Navarro guilty of grave misconduct, and reimposed the penalty of dismissal. Navarro’s motion for reconsideration was denied by the CSC.
ISSUE
Whether the Civil Service Commission acted with grave abuse of discretion or in excess of jurisdiction in taking cognizance of and deciding EPZA’s appeal from the MSPB decision exonerating Navarro from the administrative charge.
RULING
The Supreme Court granted the petition. The Court ruled that under P.D. 807 (The Philippine Civil Service Law), the Civil Service Commission has no appellate jurisdiction over decisions of the Merit Systems Protection Board that exonerate officers or employees from administrative charges. The right to appeal is a statutory privilege, and the law only allows appeals by the “party adversely affected by the decision,” which refers to the government employee against whom the administrative case is filed. Since Navarro was exonerated by the MSPB, EPZA, as the complainant, was not the party adversely affected and therefore had no legal personality to appeal. Consequently, the CSC acted without jurisdiction in entertaining the appeal. The Court set aside the CSC decision and resolution and reinstated and affirmed the decisions of the MSPB.