GR 160195; (October, 2006) (Digest)
G.R. No. 160195 ; October 30, 2006
CIVIL SERVICE COMMISSION, petitioner, vs. FLORELIO U. MANZANO, respondent.
FACTS
Respondent Florelio U. Manzano, a Department Manager II at the Land Bank of the Philippines (LBP) Mt. Province Field Office, was administratively charged with grave misconduct and conduct grossly prejudicial to the best interest of the service. The charges stemmed from irregularities in agricultural loan releases from 1990 to 1992 under his supervision, including approving loans where proceeds were used to pay off cooperatives’ existing debts instead of being lent to members, and instructing staff not to document adverse findings. The LBP dismissed him from service.
Manzano appealed to the Civil Service Commission (CSC). The CSC dismissed his appeal for being filed out of time, ruling that the 15-day reglementary period to appeal commenced from his receipt of the LBP Board of Directors’ resolution, not from a later denial of his motion for reconsideration. The Court of Appeals reversed the CSC, ordering reinstatement of Manzano’s appeal, holding that the period should be reckoned from the denial of his motion for reconsideration.
ISSUE
Whether the Court of Appeals erred in ruling that Manzano’s appeal to the CSC was timely filed.
RULING
Yes, the Court of Appeals erred. The Supreme Court reinstated the CSC’s ruling that the appeal was filed out of time. The legal logic is grounded in the explicit procedural rule under the Uniform Rules on Administrative Cases in the Civil Service. For decisions rendered by heads of agencies, like the LBP President in this case, the aggrieved party has a 15-day period to appeal to the CSC reckoned from receipt of the decision. The filing of a motion for reconsideration does not toll or interrupt this running of the period. Since Manzano received the LBP decision on October 25, 1996, his appeal to the CSC filed on November 18, 1996, was beyond the 15-day deadline. Procedural rules on reglementary periods are mandatory and jurisdictional; failure to comply renders the decision final and executory. The Court emphasized that while technicalities may be relaxed for substantive justice, Manzano failed to show compelling reasons for such liberality. Thus, the CSC correctly dismissed his appeal for being filed late.