G.R. No. 107590 February 21, 1995
PAMANTASAN NG LUNGSOD NG MAYNILA (PLM), petitioner, vs. CIVIL SERVICE COMMISSION (CSC), PAMANTASAN NG LUNGSOD NG MAYNILA FACULTY ORGANIZATION (PLMFO), ROBERTO AMORES, ROLANDO AUSTRIA, VICENTE BANAGALE, NEMENCIO CABATUANDO, MANOLO HINA, ELEANOR JIMENEZ, ANITA LEYSON, JONATHAN MANZANO, JOSE MEJIA, ESTELITA PINEDA, LORDEO POQUIZ, ALFREDO RAZON, MA. ZELDA REYES, SALVACION RODRIGUEZ, BELINDA SANTOS, and VIRGILIO ZAMORA, respondents.

FACTS

The sixteen individual private respondents were full-time instructors of petitioner Pamantasan ng Lungsod ng Maynila (PLM) under “temporary contracts” renewable yearly. They were members of the Pamantasan ng Lungsod ng Maynila Faculty Organization (PLMFO). On April 24, 1990, PLM sent them uniform notices of termination informing them of the expiration of their temporary appointments on May 31, 1990, and the non-renewal of their appointments for the school year 1990-1991. PLM advised that their retention was not recommended by their respective Deans. On May 29, 1990, private respondents, through PLMFO, filed a verified complaint for illegal dismissal and unfair labor practice with the Civil Service Commission (CSC). The CSC referred the case to the Public Sector Labor-Management Council (PSLMC). After proceedings, the PSLMC, in a Resolution dated December 16, 1991, found PLM guilty of unfair labor practice and held that private respondents should be reinstated. PLM’s petition for certiorari to the Supreme Court (G.R. No. 105157) seeking annulment of the PSLMC resolutions was dismissed for failure to submit the required forum-shopping certification, and this dismissal became final and executory. The PSLMC then transmitted the case to the CSC for appropriate action. The CSC, in its Resolution No. 92-814 dated June 25, 1992, sustained the PSLMC’s findings and directed the reinstatement of private respondents with back salaries. PLM’s motion for reconsideration was denied. PLM then filed the instant petition for certiorari, arguing that the CSC acted with grave abuse of discretion by adopting the PSLMC’s findings without conducting its own hearing, thereby denying PLM due process, and by ordering reinstatement despite the expiration of the temporary contracts.

ISSUE

Whether the Civil Service Commission committed grave abuse of discretion in adopting the findings of the Public Sector Labor-Management Council and ordering the reinstatement of private respondents without conducting further proceedings of its own.

RULING

The Supreme Court DISMISSED the petition for certiorari and AFFIRMED the appealed resolutions of the Civil Service Commission. The Court held that the PSLMC’s finding that the non-renewal of the private respondents’ contracts was motivated by their union activities (unfair labor practice) was conclusive on the parties, as the Court’s earlier resolution in G.R. No. 105157 dismissing PLM’s challenge to the PSLMC resolution had long become final and executory. When the PSLMC referred the case to the CSC for “appropriate action,” it meant the CSC should take the necessary steps to reinstate the illegally dismissed employees. The CSC’s adoption of the PSLMC’s findings, under the circumstances, was not a denial of due process. The temporary restraining order issued by the Court on May 18, 1993, was LIFTED.