G.R. No. 151110 September 11, 2008
SPL. POL. LT. RAMON C. TORREDES, Petitioner, versus CARLOS VILLAMOR, Respondent.

FACTS

Petitioner Special Police Lieutenant Ramon C. Torredes, Deputy Station Commander of the Mactan Economic Zone (MEZ) Police Force, was administratively charged before the Philippine Economic Zone Authority (PEZA) based on complaints from the MEPZA Drivers’ Association, led by its president, respondent Carlos Villamor. The charges included weekly exaction of P1,000.00 from the association without official receipts, demanding a lechon for his birthday, and pushing and threatening a member, Warden Sinangguti, after the payments and demand were not met. After investigation and petitioner’s written explanation denying the charges, PEZA found petitioner liable for grave misconduct and conduct grossly prejudicial to the best interest of the service under the Administrative Code of 1987 and dismissed him from the service. Petitioner appealed to the Civil Service Commission (CSC), which affirmed the PEZA ruling. Petitioner then filed a petition for review under Rule 43 of the Rules of Court before the Court of Appeals (CA), which dismissed the petition for failure to implead PEZA as a respondent. Petitioner now challenges this dismissal, arguing that PEZA, as the disciplining authority, is not an adverse party required to be impleaded under Rule 43, and that his failure to do so should not merit outright dismissal.

ISSUE

Whether the Court of Appeals correctly dismissed petitioner’s appeal for failure to implead the Philippine Economic Zone Authority (PEZA) as a respondent under Rule 43 of the Rules of Court.

RULING

Yes, the Court of Appeals correctly dismissed the petition. The Supreme Court affirmed the dismissal, holding that PEZA is an indispensable party and an adverse party in the appeal. As petitioner’s employer and the disciplining authority that imposed the penalty of dismissal, PEZA had a direct interest in the case and would be adversely affected by a reversal of its decision. The Court rejected petitioner’s argument that only the original complainant, respondent Villamor, was the adverse party, emphasizing the administrative nature of the case and petitioner’s status as a public officer. The Court further found that the factual findings of PEZA and the CSC, which established petitioner’s guilt through substantial evidence, were accorded finality. Consequently, the Supreme Court dismissed the petition and affirmed the decisions of PEZA and the CSC dismissing petitioner from the service.