G.R. No. 140917; October 10, 2003
Menelieto A. Olanda, petitioner, vs. Leonardo G. Bugayong, Philippine Merchant Marine Academy, Michael Dumangeng, PMMA Board of Investigation, Alfredo Joson, Lauro Del Rosario, Aurora Borromeo, Emmanuel Santos, Marlowe Reyes, Tomas Aquino, Normelita Yaneza and Pedro Dulay, respondents.

FACTS

Petitioner Menelieto A. Olanda, then Dean of the College of Marine Engineering at the Philippine Merchant Marine Academy (PMMA), was among several officers who filed a graft complaint with the Ombudsman against PMMA President Leonardo Bugayong. Following a live radio interview where Olanda discussed the complaint, Bugayong charged him administratively for misusing classified information. After an investigation, Olanda was relieved as Dean, designated to another post, and subsequently suspended for three months for violating the PMMA Faculty Handbook and civil service rules.
Olanda filed a petition for quo warranto, mandamus, and prohibition with the Regional Trial Court (RTC) of Iba, Zambales, challenging his relief and suspension and claiming respondent Michael Dumangeng was usurping his position as Dean. The RTC dismissed the petition on the ground that Olanda failed to exhaust administrative remedies. Olanda’s motion for reconsideration was denied, prompting this petition for review.

ISSUE

Whether the Regional Trial Court had jurisdiction over Olanda’s petition assailing his relief and reassignment as a PMMA employee.

RULING

The Supreme Court denied the petition, ruling that the RTC lacked jurisdiction over the case. The legal logic is anchored on the nature of the PMMA as a government-owned and controlled corporation with an original charter created under Republic Act No. 3680. Consequently, its employees fall under the jurisdiction of the Civil Service Commission. Disciplinary cases and personnel actions, including appointments, promotions, transfers, reassignments, demotions, and separations, are within the exclusive jurisdiction of the Civil Service Commission as the sole arbiter of such controversies.
The Court emphasized that the proper remedy for Olanda was to appeal the administrative decision to the Civil Service Commission, not to file a petition with the RTC. Citing precedent, the Court held that the trial court committed an error in taking cognizance of the petition. Since the RTC lacked jurisdiction from the outset, it should have dismissed the case outright. This jurisdictional defect rendered it unnecessary for the Supreme Court to address the specific errors Olanda assigned regarding exhaustion of administrative remedies or the filing of answers by other respondents. The dismissal by the RTC was thus affirmed, albeit on the correct ground of lack of jurisdiction.