GR 119155; (January, 1996) (Digest)
G.R. No. 119155 ; January 30, 1996
VICTORINA A. CRUZ, petitioner, vs. COURT OF APPEALS, HON. SALVADOR M. ENRIQUEZ, JR., Secretary of the Department of Budget and Management, HON. ARMAND V. FABELLA, Secretary of the Department of Education, Culture and Sports, and NORMA ABRACIA, School Division Superintendent, Division of City Schools, 3rd District, Caloocan City, respondents.
FACTS
Petitioner Victorina A. Cruz was a Guidance and Counselling Coordinator III at Valenzuela Memorial High School. Following the nationalization of secondary school teachers under Executive Order No. 189, her position was reclassified as Guidance Counselor with a reduced salary. Cruz appealed to the Merit Systems Protection Board (MSPB) of the Civil Service Commission, seeking an upgrade. The MSPB, in a 1990 Decision, granted her appeal and ordered the reclassification of her position and payment of salary differentials, later specifying an upgrade to Guidance Services Specialist II, Salary Grade 16 under Republic Act No. 6758 (Salary Standardization Law). The Department of Budget and Management (DBM) refused to implement the MSPB’s order, contending the MSPB lacked jurisdiction over position classification and reclassification matters.
ISSUE
Whether the Merit Systems Protection Board (MSPB) had jurisdiction to reclassify the petitioner’s position and order the corresponding salary adjustment.
RULING
The Supreme Court ruled that the MSPB acted without jurisdiction. The legal logic is anchored on the distinct statutory mandates of different government bodies. Jurisdiction over the classification and reclassification of government positions, including the determination of appropriate salary grades, is vested by law exclusively in the Department of Budget and Management (DBM) through the Compensation and Position Classification Board. This authority is explicitly provided under Presidential Decree No. 985, as amended, and subsequently under the Administrative Code of 1987. The MSPB’s primary function is to hear and decide administrative cases involving personnel actions and merit system violations, not to adjudicate classification disputes which are essentially legislative or administrative in nature. Since the MSPB’s 1990 Decision involved a reclassification action—a function outside its statutory competence—it was rendered void for lack of jurisdiction. The Court of Appeals correctly dismissed the petition for mandamus. The proper recourse for the petitioner was to pursue her grievance through the DBM.