GR 135805 Romero (Digest)
G.R. No. 135805 . April 29, 1999.
CIVIL SERVICE COMMISSION, petitioner, vs. PEDRO O. DACOYCOY, respondent.
FACTS
This case involves the legal personality of the Civil Service Commission (CSC) to appeal a decision of the Court of Appeals. The Court of Appeals had exonerated respondent Pedro O. Dacoycoy from an administrative charge, thereby reversing the CSC’s own finding of guilt. The CSC filed the instant petition, challenging the appellate court’s decision.
ISSUE
Does the Civil Service Commission possess the legal personality to appeal a decision of the Court of Appeals that reverses the Commission’s administrative decision?
RULING
No. The Civil Service Commission lacks the legal personality to appeal such a decision. A thorough examination of the governing laws—P.D. No. 807 (Civil Service Law), Executive Order No. 292 (Revised Administrative Code), and the implementing Omnibus Rules—reveals no legal basis for the CSC to act as an appealing party. The CSC is constitutionally designed as the central personnel agency and a disciplining authority. It performs quasi-judicial functions, acting as an impartial tribunal to hear and decide administrative cases commenced by others. Section 34, Rule XIV of the Omnibus Rules explicitly enumerates who may commence proceedings: the Secretary of a department, head of office, head of a local government unit, chief of agency, regional director, or any other person. The CSC itself is not listed as a party complainant or respondent. The principle of expressio unius est exclusio alterius applies; the express mention of these parties excludes the CSC.
Consequently, the CSC is not a party to the administrative proceedings it adjudicates. An “aggrieved party” entitled to elevate a CSC decision to the Court of Appeals via certiorari refers to the original complainant or the respondent government employee. The CSC is neither. While the CSC is named as a nominal party when its decision is appealed, this is a procedural formality for review and enforcement. Actively appealing a judgment of exoneration transforms the CSC from a neutral adjudicator into an adversarial combatant, which is incompatible with its quasi-judicial role. By analogy, a judge does not appeal a higher court’s reversal of his decision. Therefore, the CSC has no legal standing to file the instant petition.