G.R. No. 149451 ; May 8, 2003
REMEDIOS S. PADILLA, petitioner, vs. THE HONORABLE CIVIL SERVICE COMMISSION and DEPARTMENT OF LABOR AND EMPLOYMENT, respondents.

FACTS

Petitioner Remedios Padilla was originally a permanent Clerk II at the Ministry of Labor and Employment. In 1983, she was promoted to Labor Development Assistant, but the Civil Service Commission (CSC) disapproved this appointment in 1985 due to her lack of the required eligibility. Subsequently, petitioner voluntarily resigned from the service in May 1985 citing personal reasons. After passing the Career Service Professional Examination later that year, she re-applied and was re-hired by the Department of Labor and Employment (DOLE) in 1988 under a series of temporary casual appointments, including as Casual Research Assistant and Casual Technical.
When the Salary Standardization Act led to the abolition of casual positions, DOLE offered petitioner the available permanent position of Clerk II in late 1989, which she declined. She instead accepted another temporary appointment as Casual Clerk III, which expired in June 1990 and was not renewed. Petitioner then sought reinstatement to a permanent position, claiming her earlier civil service eligibility and prior permanent status entitled her to security of tenure.

ISSUE

Whether the termination of petitioner’s casual employment was legal and whether the CSC properly dismissed her complaint for reinstatement to a permanent position.

RULING

The Supreme Court denied the petition, ruling the termination was legal and the CSC’s dismissal was proper. The legal logic is anchored on the nature of petitioner’s employment and the consequences of her voluntary resignation. When petitioner resigned in 1985, she voluntarily severed all her employment ties and abdicated any rights attached to her former permanent position. Her re-employment under a series of casual appointments beginning in 1988 constituted an entirely new employment relationship, governed by the terms of those temporary contracts. As a casual employee, she enjoyed no security of tenure; her employment was co-terminous with the specific period stated in each appointment and dependent on the pleasure of the appointing authority.
The Court further held that petitioner was estopped from demanding a permanent position. DOLE had already offered her the permanent position of Clerk II in 1989, which she knowingly declined. By refusing this offer and opting for another casual appointment, she forfeited any claim to reinstatement under Section 24(d) of P.D. 807, which applies only to those unjustly removed. Since her separation in 1990 resulted merely from the expiration of her temporary contract, no notice or hearing was required, and no due process violation occurred. The factual findings of the CSC and the Court of Appeals, which concluded there was no illegal dismissal, are binding and supported by the record.