G.R. No. 108824 September 14, 1994
Dennis C. Lazo, petitioner, vs. Civil Service Commission, respondents.

FACTS

The Civil Service Commission (CSC) received an anonymous letter alleging that petitioner Dennis C. Lazo purchased his civil service eligibility. An initial investigation found the complainant fictitious and recommended dismissal. However, due to the allegation’s gravity, the CSC rechecked Lazo’s examination answer sheets. This rechecking revealed his actual score was 34.48%, not the 76.46% indicated on his certificate of eligibility. The CSC subsequently filed administrative charges against Lazo. After a formal investigation, the CSC dismissed the charges for lack of evidence linking Lazo to any irregularity in Resolution No. 92-837. Nevertheless, in the same resolution, the CSC revoked his eligibility as null and void.
Lazo moved for reconsideration, arguing the revocation violated his right to due process, specifically the opportunity to examine his answer sheet and contest the finding. The CSC denied his motion, stating the revocation was a necessary action to safeguard the integrity of the examinations and did not require formal proceedings since it was based on a mere re-evaluation of documents using a standard answer key.

ISSUE

Whether the Civil Service Commission acted with grave abuse of discretion and violated petitioner’s right to due process by unilaterally revoking his civil service eligibility without a formal investigation or hearing.

RULING

The Supreme Court ruled that the CSC did not commit grave abuse of discretion nor violate due process. The Constitution mandates the CSC as the central personnel agency with the authority to determine qualifications for the civil service. This power to issue certificates of eligibility inherently includes the power to revoke them when discovered to be null and void. While notice and hearing are generally required, they were not indispensable in this specific context. The revocation was based solely on a ministerial re-evaluation of Lazo’s examination papers against a pre-existing standard answer key—a purely documentary review within the CSC’s records. This action did not involve an adjudication of facts requiring an evidentiary hearing.
The principle of res ipsa loquitur applied; the discrepancy between the recorded score and the actual score spoke for itself. Furthermore, any procedural defect was cured when Lazo filed a motion for reconsideration, which the CSC duly entertained. In that motion, Lazo failed to substantively demonstrate that his correct score was 76.46%, merely arguing his non-participation in the anomaly. The revocation of the void certificate did not contradict the dismissal of the administrative charges. The finding of insufficient evidence of his personal wrongdoing was separate from the objective fact, established by rechecking, that he failed the examination. A void certificate confers no vested right. The petition was dismissed for lack of merit.