G.R. No. 153837 ; July 21, 2010
ENGR. JOB Y. BESANA, HON. RONALDO B. ZAMORA, and HON. CONRADO M. ESTRELLA III, Petitioners, vs. RODSON F. MAYOR, Respondent. AKLAN ELECTRIC COOPERATIVE, INC., Intervenor.

FACTS

Respondent Rodson F. Mayor filed an administrative complaint before the National Electrification Administration (NEA) against petitioner Job Y. Besana, then General Manager of Aklan Electric Cooperative, Inc. (AKELCO). After investigation, the NEA Board of Administrators, through Resolution No. 41 dated June 25, 1992, approved Besana’s dismissal from service. Besana did not appeal this resolution. Subsequently, Besana filed a complaint before the National Labor Relations Commission (NLRC), which initially ruled in his favor but was ultimately reversed on appeal, dismissing his complaint for lack of merit. Besana’s petition to the Supreme Court was dismissed for procedural deficiencies.
In a separate development, the NEA Board passed Resolution No. 12 on March 5, 1994, authorizing a review of the administrative case against Besana. Following the review committee’s report, the NEA Board issued Resolution No. 56 on September 30, 1994, which modified the earlier penalty from dismissal to a one-year suspension without pay. Respondent Mayor then appealed this modifying resolution to the Office of the President (OP). The OP, through its Resolution dated March 30, 2000, set aside the NEA’s Resolution No. 56 and reinstated the original penalty of dismissal from Resolution No. 41. Besana appealed the OP’s decision to the Court of Appeals.

ISSUE

Whether the Court of Appeals erred in nullifying the Office of the President’s Resolution which reinstated the penalty of dismissal against Besana, based on the respondent Mayor’s lack of legal standing to appeal the NEA’s modifying resolution to the OP.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The core legal principle is that for a party to have standing to appeal an administrative decision, they must be “aggrieved” by it, meaning their legal right must be adversely affected. The NEA’s Resolution No. 56, which reduced Besana’s penalty to suspension, was favorable to Besana and adverse to the interests of the complainant, Mayor. However, Mayor, as a mere complainant and a member of AKELCO, did not possess a clear, direct legal right that was personally and substantially injured by the reduction of penalty. His interest was too general and indistinguishable from that of the entire cooperative membership.
The Office of the President’s act of entertaining Mayor’s appeal and subsequently reinstating the dismissal was therefore void for lack of jurisdiction, as it was initiated by a party without legal standing. An appeal by a non-aggrieved party does not confer jurisdiction upon the appellate body. Consequently, the NEA’s Resolution No. 56, which imposed the lesser penalty of suspension, attained finality. The Court emphasized that administrative finality and the doctrine of exhaustion of administrative remedies are grounded on the respect for the expertise of specialized agencies. Since the NEA Board’s modifying resolution was not properly appealed by a party with legal standing, it became final and executory, and the OP had no authority to disturb it.