GR 158737; (August, 2004) (Digest)
G.R. No. 158737 ; August 31, 2004
CIVIL SERVICE COMMISSION, petitioner, vs. SATURNINO DE LA CRUZ, respondent.
FACTS
Respondent Saturnino de la Cruz was promotionally appointed as Chief Aviation Safety Regulation Officer in the Air Transportation Office (ATO) in November 1994, an appointment initially attested by the Civil Service Commission (CSC). A protest was filed by Annabella Calamba, alleging de la Cruz lacked the required four-year supervisory experience. The CSC-NCR initially upheld the protest and recalled the approval of his appointment. However, in a conflicting subsequent letter, the same CSC-NCR Director granted the request of the ATO Executive Director and affirmed the approval, reasoning that de la Cruz had since acquired the necessary experience.
This led to conflicting directives. Calamba sought implementation of the first ruling. The CSC, treating her request as an appeal, issued Resolution No. 98-2970 disapproving de la Cruz’s appointment and ordering his reversion to his former position. His motion for reconsideration was denied. De la Cruz then elevated the case to the Court of Appeals, which set aside the CSC resolutions and approved his appointment. The CSC filed this petition for review.
ISSUE
Whether the Civil Service Commission committed grave abuse of discretion in disapproving the promotional appointment of Saturnino de la Cruz.
RULING
The Supreme Court denied the CSC’s petition and affirmed the Court of Appeals. The legal logic centers on the principle that appointments are determined by qualifications possessed at the time of appointment, not those acquired subsequently. The CSC’s disapproval was based on de la Cruz’s alleged lack of the four-year supervisory experience requirement as of his appointment date in 1994.
However, the Court found the CSC’s factual determination to be unsupported by the evidence on record. The record contained office orders and designations showing that de la Cruz had been assigned to and had discharged supervisory functions well before his 1994 appointment. The CSC’s own contradictory issuances and its failure to properly consider the documentary evidence submitted by the ATO constituted a denial of due process. When an administrative body, like the CSC, acts in a manner that is arbitrary, capricious, or issued without basis in the evidence, it commits grave abuse of discretion. The Court held that the CSC’s resolutions were issued with such abuse, as they disregarded competent proof of de la Cruz’s compliance with the experience requirement. Consequently, his appointment was deemed valid and properly approved.