GR 146175; (June, 2008) (Digest)
G.R. No. 146175 ; June 30, 2008
SIMEON M. VALDEZ, petitioner, vs. GOVERNMENT SERVICE INSURANCE SYSTEM, respondent.
FACTS
Petitioner Simeon M. Valdez filed an application for retirement benefits with the GSIS, seeking credit for various services. He claimed credit for his tenure as a Congressman, as a Director of the Philippine Veterans Investment Development Company (PHIVIDEC), as a Member of the Board of Regents of Mariano Marcos State University (MMSU), and as a Director of the Manila Economic and Cultural Office (MECO). The Civil Service Commission (CSC), in an opinion sought by Valdez, denied the accreditation of his services in MECO, PHIVIDEC, and MMSU for retirement computation. The CSC ruled that MECO, as a subsidiary corporation governed by the Corporation Code and not by an original charter, is not part of the civil service. For his concurrent positions at PHIVIDEC and MMSU, the CSC cited rules against granting leave and retirement benefits for part-time services to avoid double compensation.
Aggrieved, Valdez filed a special civil action for certiorari under Rule 65 with the Court of Appeals, assailing the CSC’s opinion. The CA dismissed the petition, upholding the CSC’s findings. Valdez then elevated the case to the Supreme Court via a petition for certiorari, arguing that the CA committed grave abuse of discretion in affirming the CSC.
ISSUE
Whether the Court of Appeals committed grave abuse of discretion in upholding the CSC’s opinion which denied the accreditation of petitioner’s services in MECO, PHIVIDEC, and MMSU for the computation of his retirement benefits.
RULING
The Supreme Court dismissed the petition. The Court clarified that a special civil action for certiorari under Rule 65 is a remedy solely for correcting errors of jurisdiction, not errors of judgment. An error of jurisdiction occurs when a tribunal acts without or in excess of its authority, while an error of judgment involves a mistaken evaluation of facts or law within its competence. The petitioner’s arguments essentially questioned the CSC’s and the CA’s factual and legal conclusions regarding the nature of his employment and the applicable retirement laws. These constitute alleged errors of judgment, not jurisdiction.
The Court found no showing that the CA acted capriciously, whimsically, or in a despotic manner amounting to lack or excess of jurisdiction. The proper remedy for correcting such evaluative errors would have been an appeal, not certiorari. Since the petition was filed under the wrong mode of review, it warranted dismissal. The Court affirmed the CA’s decision, which sustained the CSC’s opinion that the disputed services were not creditable government service for retirement purposes under the governing laws and rules.